TRUSTe

TRACOM Policy on Data and Privacy

Effective Date: 25 May 2018

The TRACOM Corporation, doing business as TRACOM Group (collectively, "TRACOM", "We", "Us", or "Our"), has a strong commitment to protect the rights and privacy of every person who participates in our services. TRACOM never sells, leases, or rents personal data to anyone. This privacy policy applies to certain websites owned and operated by TRACOM and describes how TRACOM collects, processes, uses, secures, and shares the personal data you provide on these web sites: https://www.tracommax.com, https://www.tracomlearning.com, and https://www.socialstylenavigator.com, (collectively “TRACOM systems”). It also describes the choices available to you regarding our use of your personal data and how you can access and update this information.

TRACOM processes the personal data it receives, in The United States (U.S.). TRACOM participates in and has certified its compliance with the EU-U.S. Privacy Shield framework and the Swiss-U.S. Privacy Shield Framework. TRACOM is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on the Privacy Shield framework, to the framework's applicable principles. To learn more about the Privacy Shield framework, visit the U.S. Department of Commerce's Privacy Shield List [https://www.privacyshield.gov/]

TRACOM is responsible for the processing of personal data it receives, under each Privacy Shield framework, and subsequently transfers to a third party acting as an agent on its behalf. TRACOM complies with the Privacy Shield principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield frameworks, TRACOM is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, TRACOM may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

TRACOM delivers assessment and training services to our clients. In the course of delivering these services, we gather personal data on or about individuals. Personal data includes, but is not limited to:

• Contact Information (e.g. First and last name, email address, telephone number (Administrators only))

• Demographic Information - Optional (e.g. State/Province, Country, Age Range, Gender , Education Level, Primary Occupation, Industry, Organization Level, Range of Time Worked at Company)

• Identifying Information (e.g. Username, Password, Security Questions and Responses)

• Behavioral Information (e.g. Assessment Responses)

• Sensitive personal data gathered includes an optional Ethnicity question (United States respondents only)

We use personal data to authenticate authorized access to our websites and to process the assessment data gathered into Learner Profile Reports, used by the Learners in group and individual training and coaching sessions. Your employer has contracted with TRACOM to make our services available to certain individuals (“Learners”) for their personal and professional development. If you are a Learner and do not wish to provide personal data, a sample Learner Profile Report can be made available to you. This will reduce the applicability of the information to you. If you have been asked to provide feedback about a coworker but do not wish to provide personal data, the Learner will not receive the benefit of your valuable feedback.

TRACOM uses technologies such as cookies or similar technologies within our websites. We may use cookies, for example, to manage browser sessions and user preferences. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.

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 regularly analyze assessment and demographic responses, including ethnicity responses, and the results are used by TRACOM to update and validate our assessments and are occasionally published, in summary form only, in research reports designed for general circulation. Individuals are never identified in these reports. Specific organizations are identified only if we receive prior written approval from the organization.

Personal data collected about or from an individual is considered confidential by TRACOM. Only authorized personnel (TRACOM Administrators and Facilitators, and client Administrators and Facilitators) have access to personal data. However, once individual Learner Profile Reports have been delivered to the client’s Learners, Administrators, or Facilitators, these materials are no longer within the control of TRACOM.

The security of your personal data is important to TRACOM. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. When you enter personal data, we encrypt the transmission of that information using secure socket layer technology (SSL). No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of your personal information, you can contact us at tracomlearning@tracom.com.

We may provide your personal information to companies that provide services to help us with our business activities such as [fulfilling orders, payment processing, providing cloud computing infrastructure, or providing customer service]. These companies are authorized to use your personal information only as necessary to provide these services to us.

In the event of an asset sale, merger, consolidation, restructuring, reorganization, liquidation or other similar transaction involving TRACOM, we may transfer some or all personal data to the successor company. You will be notified via email and/or a prominent notice on our web site of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.

We may disclose personal data when we believe such disclosure is required by law, such as to comply with a subpoena, 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, or to any other third party with your prior consent.

Upon request TRACOM will provide you with information about whether we hold any of your personal information. We use your personal data as necessary, to comply with our legal obligations, resolve disputes, and enforce our agreements and will retain it until instructed to remove it by the TRACOM Client, or you (under limited circumstances). TRACOM acknowledges that you have the right to access your personal information. TRACOM has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to TRACOM’s client (the data controller). If requested to remove data we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

If you are the subject of one of our multi-rater assessments, we will ask you to invite people to participate as your Raters. We will ask you for their names and email addresses. We will send your Raters a one-time email inviting them to visit the assessment website and optionally, send them periodic reminders. TRACOM stores this information for the sole purpose of sending these emails and measuring the progress of your Raters in responding to the assessment. Accordingly, if you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at the contact information below.

TRACOM follows the data privacy requirements of the European Union’s General Data Protection Regulation (GDPR), among others, Under the GDPR, individuals may exercise their data privacy rights, by following the instructions for each of the rights listed below:

The Right of Access and Rectification

Individuals have the right to access, view, and change their personal data stored in the TRACOM systems. The process for doing this varies depending on the website, and the role of the user, as follows:

MAX (https://www.tracommax.com)
Client Administrators
- Can view/edit the personal data of other individuals for which they are authorized via the Individual Edit screen.
- Can view/edit their personal data via the My Information Edit screen.

Facilitators
- Can view/edit their personal data via the My Information Edit screen.

TRACOM Learning (https://www.tracomlearning.com)
Learners/Raters
- Can view/edit their personal data via the Change My Information screen.
- Learners using the Survey Codes access method need to contact their Client Administrator to have their personal data changed. The Client Administrator name and email address are located on your invitation and reminder emails.

SOCIAL STYLE Navigator (https://www.socialstylenavigator.com)
Learners
- Can view/edit their personal data via the Change My Information screen.

The Right to Erasure (Right to Be Forgotten)

TRACOM will maintain personal data until an authorized representative of our client notifies TRACOM, in writing, to remove the personal data.

Individuals have the right to request that personal data be removed from the TRACOM systems. Any request to TRACOM to remove personal data must come from a Client Administrator. To exercise this right, an individual (Learner, Rater, Administrator, or Facilitator) contacts the Client Administrator to request his/her personal data be removed. The Client Administrator name and email address are located on your invitation and reminder emails. Upon notification from the Client Administrator, TRACOM will remove the individual’s personal data from the TRACOM systems.

The Right to Restriction of Processing

Individuals have the right to restrict the processing of personal data in the TRACOM systems. Any request to restrict personal data processing must come from a Client Administrator using the procedure noted under The Right to Be Forgotten above:

The Right to Data Portability

Individuals have the right to receive their personal data from the TRACOM systems in a commonly used, machine readable format so that it can then be used for a variety of other purposes. Any request to receive personal data must come from a Client Administrator using the following procedure:

1. An Individual (Learner, Rater, Administrator, or Facilitator) contacts the Client Administrator to request his/her personal data be received in a machine readable format. The Client Administrator name and email address is located on your invitation and reminder emails.

2. A Client Administrator submits a request to TRACOM in writing that personal data be made available for an individual.

3. TRACOM evaluates the request to make sure it can be fulfilled. If there is any reason the request can’t be fulfilled, TRACOM will notify the Client Administrator, in writing. Otherwise, TRACOM fulfills the request and forwards the requested information to the Client Administrator, to provide to the individual.

The Right to Object

Individuals have the right to approve or disapprove using their personal data in the TRACOM systems. An individual is nominated by his/her employer to participate in the TRACOM services, pursuant to the employer’s legitimate interests.

Any request to remove consent must come from a Client Administrator using the procedure noted under The Right to Be Forgotten, above:

TRACOM may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

This statement was prepared to help participants in TRACOM's programs understand our policy on privacy and data use. If you have any questions regarding this Privacy Policy, you can contact us at:

The TRACOM Corporation
6675 South Kenton Street, Suite 118
Centennial, Colorado, USA 80111

Email: tracomlearning@tracom.com