Data Protection Addendum

ProTrainings, LLC has adopted this Data Protection Addendum Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that ProTrainings obtains from Customers located in the European Union and the United Kingdom.

ProTrainings complies with the (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the US Department of Commerce. ProTrainings 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 and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-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 www.dataprivacyframework.gov.

The Federal Trade Commission (FTC) has jurisdiction over ProTrainings's compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

All ProTrainings employees who handle Personal Data from Europe are required to comply with the Principles stated in this Policy.

Capitalized terms are defined in Section 14 of this Policy.

I. SCOPE

This Policy applies to the processing of Individual Customer Personal Data that ProTrainings receives in the United States concerning Individual Customers who reside in the European Union. ProTrainings provides products and services to businesses and consumers.

This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)

II. RESPONSIBILITIES AND MANAGEMENT

ProTrainings has designated the IT Department to oversee its information security program, including its compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. The IT Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to support@protrainings.uk.

ProTrainings will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. ProTrainings personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that ProTrainings has undertaken to protect Personal Data.

III. RENEWAL / VERIFICATION

ProTrainings will adhere to EU-U.S. DPF and the UK Extension to the EU-U.S. DPF for as long as information that collected under its EU-U.S. DPF and the UK Extension to the EU-U.S. DPF certification is retained.

ProTrainings will renew its EU-U.S. DPF and the UK Extension to the EU-U.S. DPF certification annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.

Prior to the re-certification, ProTrainings will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, ProTrainings will undertake the following:

1. Review this Data Protection Addendum policy and its publicly posted website privacy policy to ensure that these policies accurately describe the practices regarding the collection of Individual Customer Personal Data
2. Ensure that the publicly posted privacy policy informs Individual Customers of ProTrainings's participation in the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF program and where to obtain a copy of additional information (e.g., a copy of this Policy)
3. Ensure that this Policy continues to comply with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF
4. Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (ProTrainings may do so through its publicly posted website, Individual Customer contract, or both)
5. Review its processes and procedures for training Employees about ProTrainings's participation in the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF program and the appropriate handling of Individual Personal Data. Employees who fail to follow the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF complaint handling process will be disciplined accordingly.

ProTrainings will prepare an internal verification statement which shall be signed by a corporate representative, on an annual basis.

IV. COLLECTION AND USE OF PERSONAL DATA

ProTrainings provides various solutions to its Individual Customers who purchase its products. ProTrainings collects Personal Data from Individual Customers when they purchase its products, register with its website, log-in to their account, complete surveys, request information or otherwise communicate with us. For example, ProTrainings individual customers may choose to register for training, seek live support or post to a message board.

The Personal Data that we collect may vary based on the Individual Customer's interaction with our website and request for our services. As a general matter, ProTrainings collects the following types of Personal Data from its Individual Customers: contact information, including, a contact person's name, email address, password(s), mailing address, telephone number, occupation, and company name, as well as payment information (which might include credit card and/or bank account information). Individual customers have the option to log into their accounts online and to request service online, including through a live support option; we will collect information that they choose to provide to us through these portals.

When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.

The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer.

For certain products, ProTrainings serves as a service provider. In our capacity as a service provider, we will receive, store, and/or process Personal Data. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of our partners and/or agents. The information that we collect from our Individual Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Individual Customer, and as otherwise requested by our partner and/or agent.

ProTrainings uses Personal Data that it collects directly from its Individual Customers and for its partners indirectly in its role as a service provider for the following business purposes, without limitation:

1. maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to a Individual Customer);
2. satisfying governmental reporting, tax, and other requirements (e.g., import/export);
3. storing and processing data, including Personal Data, in computer databases and primary servers located in the United States and United Kingdom.
4. verifying identity (e.g., for online access to accounts);
5. as requested by the Individual Customer;
6. for other business-related purposes permitted or required under applicable local law and regulation;
7. and as otherwise required by law.

V. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA / CHOICE

Except as otherwise provided herein, ProTrainings discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.

ProTrainings may provide Personal Data to Third Parties that act as agents, consultants, vendors and contractors to perform tasks on behalf of and under our instructions. For example, ProTrainings may store such Personal Data in the facilities operated by Third Parties.

Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by ProTrainings and they must either:

1. comply with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF or another mechanism permitted by the applicable EU data protection law(s) for transfers and processing of Personal Data;
2. or agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy;

ProTrainings also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that ProTrainings 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. ProTrainings is liable for appropriate onward transfers of personal data to third parties.

Individuals have the opportunity to choose (opt out) whether their personal information is to be disclosed to third parties by contacting support@protrainings.uk. However, individuals who opt out should expect limited service-ability.

Further, individuals may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, or by sending us email us at support@protrainings.uk. Customers cannot opt out of receiving transactional emails related to their account with us.

VI. SENSITIVE PERSONAL DATA

ProTrainings does not collect Sensitive Personal Data from its Individual Customers.

VII. DATA INTEGRITY AND SECURITY

ProTrainings uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. ProTrainings has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to ProTrainings's electronic information systems requires user authentication via password or similar means. ProTrainings also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.

Further, ProTrainings uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.

VIII. NOTIFICATION

ProTrainings notifies Individual Customers about its adherence to the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF through its publicly posted website privacy policy, available at: www.protrainings.uk/privacy_policy and take Individual Customer’s approval and adherence to the current policy when they provide their information to us in the transactional process.

IX. ACCESSING PERSONAL DATA

ProTrainings personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.

X. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA

1. Right to Access. Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which ProTrainings collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and ProTrainings policies. Upon reasonable request and as required by the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, ProTrainings allows Individual Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by logging into their account profile or by contacting ProTrainings by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to ProTrainings.
2. Requests for Personal Data. ProTrainings will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If ProTrainings receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, ProTrainings will refer such Data Subject to the Individual Customer.
3. Satisfying Requests for Access, Modifications, and Corrections. ProTrainings will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

XI. CHANGES TO THIS POLICY

This Policy may be amended from time to time, consistent with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and applicable data protection and privacy laws and principles. We will make employees aware of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.

XII. QUESTIONS OR COMPLAINTS

EU Individual customers may contact ProTrainings with questions or complaints concerning this Policy at the following address: support@protrainings.uk

XIII. ENFORCEMENT AND DISPUTE RESOLUTION

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

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, ProTrainings commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. 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 www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

In the event that your complaint cannot be resolved directly with ProTrainings, or through the independent dispute resolution mechanism, you may be able to invoke binding arbitration through the Data Privacy Framework Panel. For more information on this option, please see Annex I of the EU-U.S. Data Privacy Framework Principles.

XIV. DEFINED TERMS

Capitalized terms in this Privacy Policy have the following meanings:

"Individual Customer" means an Individual customer or client of ProTrainings from EU. The term also shall include any individual agent, representative, of an individual customer of ProTrainings and all employee of ProTrainings where ProTrainings has obtained his or her Personal Data from such Individual Customer as part of its business relationship with ProTrainings.

"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics.

"Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of ProTrainings or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.

"Europe" or "European" refers to a country in the European Union withstanding any departure of the United Kingdom from the European Union.

"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available.

"Sensitive Personal Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.

"Third Party" means any individual or entity that is neither ProTrainings nor a ProTrainings employee, agent, contractor, or representative.

Version 4 - Aug 11, 2023