At Visionem, Inc. and its TCAR Education Programs and Allegro Reviews Divisions, we respect and protect the privacy of those who visit or use our web sites. When we collect information from you, we want you to know how it is used. To demonstrate our commitment to fair information practices, we have adopted leading industry privacy guidelines.
What information does this website gather?
We collect personal information such as name, address, e-mail address and billing information when you knowingly provide it to us. Our web servers or a third party web analytics company may automatically collect statistical information about your visit such as pages visited and which browsers are used to visit our site. None of this information is associated with you as an individual (see information about cookies), unless and until you establish an account on any of our sites. If information was collected, we would use these statistics to monitor our site's performance and to make it easier for you to use.
What happens when I provide personal information on this website?
When you supply information for a specific purpose such as ordering a service from any of our web sites, we use the information for the purpose of providing that service. If the way we use personally identifiable information changes, we will contact you via e-mail notifying you of this change and giving you the opportunity to opt out of such use.
What happens when I provide information to subscribe to any of your online services?
In the future, if you choose to subscribe to one of our online services, we request an accurate contact. You will be able to choose if your contact information is used to send you company and productinformation, special offers and/or newsletters.
If you become one of our customers, we store your name, purchase and usage history and billing information to allow you to manage your account. Customers have access to their account information and usage history on-line. In the future, when subscriptions are launched, they can update their personal account information at any time by selecting "My Account" from our web site menus or by contacting us using the information provided below.
As a future subscriber, you may at any time:
- Opt out. At any time after the initial subscription, you can opt out by calling Customer Service using the information provided below.
- Update your contact and personal information anytime by notifying us of changes to the information previously collected from you on-line by calling Customer Service using the information provided below.
In order to improve your experience with us, we may decide to improve our site's ability to obtain information about users. If we do, we will update this privacy statement continually to ensure that you are aware of developments in this area.
What happens when I provide information to subscribe to any of your online services?
On occasion, we share non-personally identifiable information with other companies in order to assess the results of a promotion. This information is used in aggregate only, and does not contain any information that would personally identify you. Information could be shared with one of our authorized resellers to fulfill a request for information or to follow up on an inquiry. We will list these resellers on our site if such relationships are established.
Personal information submitted to us through any of our web sites may be transferred across national boundaries and may be stored and processed in any of the countries in which we or our affiliates or our authorized resellers maintain offices, including, without limitation, the United States. You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage, and processing of your information may be undertaken by trusted vendors of Visionem, Inc. Such vendors are bound by contract not to use your personal information for their own purposes or provide it to any third parties.
What do you do with personally identifiable information?
Personal information you voluntarily supply when obtaining information, purchasing services or interacting with our advertising may be shared with authorized resellers or affiliates of us. However, you will be informed when such information is shared and will be given an opportunity to opt out. Should any changes be made in the way we use personally identifiable information, we will contact you via e-mail notifying you of this change and give you the opportunity to choose to opt out of such use.
Does this site send e-mail to site visitors?
At times, we may utilize e-mail for any of these reasons:
- To conduct online surveys
- To respond to a site visitor's e-mail
- To confirm orders placed online
- To send information that a visitor has requested
- To respond to a "Tell a Friend" request
- To reset a password
- To periodically distribute a newsletter
Occasionally, we may use opt-in e-mail lists from third parties to promote our latest offerings. In all of these situations you will be provided with direction on how to opt out of future e-mails of this nature.
What about children and privacy?
Because of the nature of our business, our web sites are not designed to appeal to children under the age of 13. Therefore, we do not knowingly attempt to solicit or receive any information from children.
How do you protect my personal information?
What is your policy regarding the GDPR (EU, 2016/679)?
Welcome to TCAR Education Programs' privacy notice in regards to the EU 2016/697 General Data Protection Regulation (GDPR).
TCAR Education Programs respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you sign up for our services from anywhere within Europe and tell you about your privacy rights and how the law protects you.
1. Important Information and Who we Are
Purpose of this Privacy Notice
This privacy notice aims to give you information on how TCAR Education Programs collects and processes your personal data when you sign up to our services.
Our services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Visionem, Inc (d/b/a TCAR Education Programs) is the controller and responsible for your personal data (collectively referred to as "TCAR Education Programs", "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Visionem, Inc. (d/b/a TCAR Education Programs)
Name or title of data privacy manager: Robert Brock
Email address: firstname.lastname@example.org
33470 Chinook Plaza, Suite 373
Scappoose, OR 97056
Telephone Number: 503-608-4900
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The Data we Collect About you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes your full name and title
- Contact Data includes email addresses, and telephone numbers.
- Financial Dataincludes your bank account and payment card details (if you are funding our course yourself) or (if you are funded by a sponsor) details of your employer so that we can check that your employer or sponsor approves funding for our services.
- Transaction Data includes details about payments from you (if you are funding our course yourself).
- Profile Data includes feedback and survey responses
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we aggregate your Profile Data to provide a summary evaluation report to the company or organisation hosting or sponsoring our course. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services).
3. How is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- sign up for one of our courses;
- provide us with feedback on one of our courses;
- make payment for our services; or
- request marketing be sent to you
- Your employer or sponsor. Where our course is organised or paid for by your employer or other sponsor we may receive personal data about you from your employer or other sponsor. That may be Identity, Contact or Financial Data.
4. How we use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
The types of lawful basis that we will rely on to process your personal data
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.
Purposes for Which we Will use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data||Lawful basis for processing including basis of legitimate interest|
|To enroll you in a course and to deliver that course to you||
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (for running our business)
To take payment for our course or to check that your sponsor will pay our fees including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to run our business or to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to make improvements to and monitor our services)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional Offers From us
We may use your Identity, Contact, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or have attended one of our courses and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside of group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary at the end of this Privacy Notice.
- External Third Parties as set out in the Glossary at the end of this Privacy Notice.
- Specific third parties such as your employer or sponsor.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
We are a business operating in the US and therefore by signing up to one of our courses your data will be transferred to us in the US. Other than that we do not transfer your personal data outside the European Economic Area (EEA).
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How Long will you use my Personal Data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our delegates (including Contact, Identity, Financial and Transaction Data) for [six] years after they have completed their course for [tax] purposes.
In some circumstances you can ask us to delete your data: see your Right to Request Erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. More details about these rights are set out in the Glossary below but they include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us.
No fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may Need From you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Other companies in our Group and who are based in the US and provide IT and system administration services.
External Third Parties
Service providers who are based in the US and provide IT and system administration services.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a "data subject access request.") This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Who do I contact if I am concerned about privacy and have questions or concerns?
You can contact Visionem or its divisions at the addresses provided below:
Correspondence by Post — Send to:
31772 SW Callahan Road
Scappoose, OR 97056