Enabl-u Technologies (“Enabl-u”), a division of ISO Crime Analytics, Inc., respects your concerns about privacy. Enabl-u has certified that, for its data management and training solutions, it abides by the Safe Harbor privacy principles as set forth by the U.S. Department of Commerce regarding the collection, storage, use, transfer and other processing of Personal Data transferred from the European Economic Area (“EEA”) or Switzerland to the United States. This Policy outlines our general policy and practices for implementing the Safe Harbor privacy principles for covered Personal Data. For purposes of this policy:
“Consumer” means any natural person who is located in the EEA or Switzerland.
“Customer” means any entity that purchases or licenses Enabl-u’s data management or training solutions or services.
“Personal Data” means any information, including Sensitive Data, that (i) is transferred to Enabl-u in the U.S. from the EEA or Switzerland, (ii) is recorded in any form, (iii) relates to an identified or identifiable Consumer, and (iv) can be linked to that individual.
“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.
Enabl-u’s Safe Harbor certification can be found at https://safeharbor.export.gov/list.aspx . For more information about the Safe Harbor principles, please visit http://www.export.gov/safeharbor . For more information about Enabl-u’s processing of Personal Data collected from Consumers on the relevant websites, please visit http://enabl-u.com/privacy.html , https://www3.apisenterprise.com/privacy.html and http://learnitcampus.com/campus300/privacy.html?company=learnit .
Enabl-u offers advanced data management and training solutions to its corporate Customers. In the course of providing these products and services, Enabl-u may access or obtain Personal Data about a corporate Customer’s Consumers or employees located in the EEA or Switzerland. Enabl-u accesses or obtains these data on behalf of its Customers for the purposes of administering, maintaining and supporting Enabl-u’s products and services. In connection with its data management and training solutions, Enabl-u acts as a service provider to its Customers and pursuant to their instructions.
Enabl-u also collects Personal Data directly from Consumers. This collection occurs, for example, when a Consumer visits Enabl-u’s relevant websites at www.enabl-u.com , www.apisenterprise.com and www.learnitcampus.com (collectively, the “Sites”), and provides Personal Data to Enabl-u on the Sites. In addition, Enabl-u obtains Personal Data, such as contact information, in connection with maintaining its Customer relationships and providing products and services to its Customers.
Enabl-u’s practices regarding the collection, storage, use, transfer, and other processing of Personal Data comply, as appropriate, with the Safe Harbor principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight.
Enabl-u provides information in its Privacy Notices available at http://enabl-u.com/privacy.html , https://www3.apisenterprise.com/privacy.html and http://learnitcampus.com/campus300/privacy.html?company=learnit regarding its practices related to Personal Data collected on the Sites. In circumstances in which Enabl-u acts as a service provider for its Customers, Enabl-u’s Customers are responsible for providing appropriate notice to their Consumers whose Personal Data are transferred to the U.S. and obtaining any requisite consent. Relevant information also may be found in privacy notices pertaining to specific data processing activities.
In circumstances in which Enabl-u collects Personal Data directly from Consumers, it offers Consumers the opportunity to choose whether Enabl-u may (i) disclose their Personal Data to certain third parties or (ii) use their Personal Data for a purpose that is incompatible with the purpose for which the information was originally collected or subsequently authorized by the individual. Consumers may contact Enabl-u as indicated below regarding the company's use or disclosure of their Personal Data.
In circumstances in which Enabl-u maintains Personal Data about Consumers with whom Enabl-u does not have a direct relationship because Enabl-u obtained or maintains the Consumers’ data as a service provider for its Customers, Enabl-u’s Customers are responsible for providing the relevant individuals with certain choices with respect to the Customers' use or disclosure of the individual’s Personal Data.
Enabl-u may disclose Personal Data without offering an opportunity to opt out (i) to service providers the Company has retained to perform services on our behalf, (ii) if it is required to do so by law or legal process, (iii) to law enforcement or other government authorities, or (iv) when Enabl-u believes disclosure is necessary to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity. Enabl-u also reserves the right to transfer Personal Data in the event it sells or transfers all or a portion of its business or assets. Should such a sale or transfer occur, Enabl-u will use reasonable efforts to direct the transferee to use the Personal Data in a manner that is consistent with Enabl-u’s privacy policies.
Except as permitted or required by applicable law, Enabl-u requires third parties to whom it discloses Personal Data and who are not subject to the European Union Data Protection Directive 95/46 or an adequacy finding to either (i) subscribe to the relevant Safe Harbor principles or (ii) contractually agree to provide at least the same level of protection for Personal Data as is required by the relevant Safe Harbor principles.
Where appropriate, Enabl-u provides Consumers with reasonable access to the Personal Data Enabl-u maintains about them. Enabl-u also provides a reasonable opportunity for Consumers to correct, amend or delete that information where it is inaccurate, as appropriate. Enabl-u may limit or deny access to Personal Data where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Safe Harbor principles. The right to access personal information also may be limited in some circumstances by local law requirements. Consumers may request access to their Personal Data by contacting Enabl-u as indicated below.
In circumstances in which Enabl-u maintains Personal Data about Consumers with whom Enabl-u does not have a direct relationship because Enabl-u obtained or maintains the Consumers’ data as a service provider for its Customers, Enabl-u’s Customers are responsible for providing Consumers with access to the Personal Data and the right to correct, amend or delete the information where it is inaccurate. In these circumstances, Consumers should direct their questions to the appropriate Enabl-u Customer. When a Consumer is unable to contact the appropriate Customer, or does not obtain a response from the Customer, Enabl-u will provide reasonable assistance in forwarding the individual’s request to the Customer.
Enabl-u takes reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Enabl-u takes reasonable steps to ensure that the Personal Data the company processes are (i) relevant for the purposes for which they are to be used, (ii) reliable for their intended use, and (iii) accurate, complete and current. In this regard, Enabl-u depends on its Consumers and Customers (with respect to Personal Data of Consumers with whom Enabl-u does not have a direct relationship) to update and correct Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized by the individuals. Consumers (and Customers, as appropriate) may contact Enabl-u as indicated below to request that Enabl-u update or correct relevant Personal Data.
Enabl-u has established procedures for periodically verifying implementation of and compliance with the Safe Harbor principles. Enabl-u conducts an annual self-assessment of its Personal Data practices to verify that the attestations and assertions the company makes about its privacy practices are true and that the company’s privacy practices have been implemented as represented.
Consumers may file a complaint concerning Enabl-u’s processing of their Personal Data with Enabl-u’s Privacy Office, whose contact information is below. Please contact Enabl-u as specified below to address any complaints regarding the company’s Personal Data practices.
If a Consumer complaint cannot be resolved through Enabl-u's internal processes, Enabl-u will cooperate with JAMS pursuant to the JAMS International Mediation Rules, which are accessible on the JAMS website at www.jamsadr.com/international-mediation-rules .
JAMS mediation may be commenced as provided for in the JAMS International Mediation Rules. The mediator may propose any appropriate remedy, such as publicity for findings of non-compliance, payment of compensation for losses incurred as a result of non-compliance, or cessation of processing of the Personal Data of the Consumer who has brought the complaint. Enabl-u will assume the costs of the administrative fees if the mediator makes a written recommendation that finds Enabl-u in breach of its duties pursuant to the Safe Harbor. The mediator or the Consumer also may refer the matter to the U.S. Federal Trade Commission, which has Safe Harbor enforcement jurisdiction over Enabl-u.
In circumstances in which Enabl-u maintains Personal Data about Consumers with whom Enabl-u does not have a direct relationship because Enabl-u obtained or maintains the Consumers’ data as a service provider for its Customers, Consumers may submit complaints concerning the processing of their Personal Data to the relevant Customer, in accordance with the Customer’s dispute resolution process. Enabl-u will participate in this process at the request of the Customer or the Consumer. If the issue cannot be resolved through the Customer’s internal dispute resolution mechanism, the Consumer may submit the complaint to the relevant data protection authority in the EEA or Switzerland.
To contact Enabl-u about questions or concerns about this Safe Harbor Privacy Policy or Enabl-u’s practices concerning Personal Data:
Write to:
Enabl-u Technologies / ISO Crime Analytics, Inc.
Attention: Law Department
545 Washington Boulevard
Jersey City, New Jersey 07310-1686
USA
Enabl-u Technologies
c/o Insurance Services Office, Ltd.
Attention: Law Department
New London House
4th Floor
6 London Street
London, England EC3R7LP
Email: privacy@enabl-u.com