Privacy Policy

At Training Management Corporation (“TMC”), we respect our customers and understand that you are concerned about privacy. Therefore, TMC has instituted policies intended to ensure that your personal information is handled securely and responsibly. We have posted this Privacy Policy to let you know what kind of information we collect, how it is handled and with whom it may be shared.

This privacy policy applies to www.tmcorp.com, www.culturalnavigator.com, http://explore.culturalnavigator.com and www.culturalorientations.com owned and operated by Training Management Corp. (“TMC”), a Berlitz Company.

We encourage you to refer to this Policy on an ongoing basis, so that you understand our current Privacy Policy.

Furthermore, we are pleased to confirm that TMC is compliant with the following privacy programs in acknowledgement of its commitment to the importance of protecting your individual personally identifiable information.

What Information Do We Collect?

a. Personal Information

We collect various types of “personal information” depending upon how you use our websites, such as:

  • When you order from us, we collect your name, address, email address, phone number, and credit card number with expiration date.
  • When you order from us, we retain a record of your purchases.
  • When you enter a sweepstakes or contest online, we usually collect your name, address, email address, and phone number. We also may ask you for additional information, such as your age, interests, product preferences, or zip code.
  • When you submit an inquiry, we need your name, email address and zip code/local country post code to respond.

You will always know when we are collecting personal information because we only collect personal information when you voluntarily submit it to us. If you do choose to give us personal information through our websites, we will collect and retain that information, and you consent to the transfer and storage of that information on our servers. If you choose not to give us personal information, we may not be able to provide you with any services you may request or require.

b. Non-Personal Information

When you use our websites, we may also collect "non-personal information," which is information that, by itself, cannot be used to identify or contact you, such as demographic information (such as your age, gender, income, education, profession, zip code, etc.) or technical information (such as your IP address, the type of browser you are using). Non-personal information may also include information that you provide us through your use of our websites, such as the terms you enter into the search functions of our websites.

c.Cookies and Similar Technologies

TMC and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

We partner with a third party to [display advertising on our website or to manage our advertising on other sites]. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt-out of interest-based advertising click here [or if located in the European Union click here]. Please note you will continue to receive generic ads.

d.  Other Disclosures

In certain situations, TMC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Additionally, TMC may share your personal information when it is necessary to comply with law or to protect our interests or property. This may include sharing your personal information with other companies, lawyers, credit bureaus, agents or government agencies in connection with issues related to fraud, credit or debt collection, and other types of criminal investigation.

The personal information provided to you in connection with the Cultural Orientations Indicator©, TMC’s cultural assessment tool, and the resulting Cultural Profile will be kept strictly confidential within a secured TMC database. Your profile will not be released to your employer or any other sponsoring organization without your authorization, which you have the option to opt-in or opt-out.

We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us.

Is My Information Secure?

TMC is committed to doing its best to maintain the security of information collected on our websites. To try to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have implemented physical, electronic, and managerial procedures to safeguard and secure the information we collect.

There is always some risk in transmitting information electronically. As we deem appropriate, we use security measures consistent with industry standards.

However, we cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet.

Access and Corrections

You may contact us any time at rita.pauls@berlitz.de to request any of the following: 1) provide you with information about whether we hold any of your personal information 2) see what personal information we have about you, if any,

3) change or correct any personal information we have about you, 4) have us delete any personal information we have about you, 5) express any concern you have about our use of your personal information. It is not technologically possible to change or delete each and every instance of the information we hold on you from our systems, and data may remain in non-erasable or aggregate form. We will respond to your request within a reasonable timeframe.

We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

Choice

You may sign-up to receive [email or newsletter or other communications from us]. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or at your member profile on our website or by contacting us at rita.pauls@berlitz.de.

What About Children's Privacy?

It currently is our policy not to knowingly collect personal information from any person under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at rita.pauls@berlitz.de. If we become aware that a child under 13 has provided us with personal information, we will endeavor to delete such information from our files as soon as possible.

If you are under 18 years of age and live in California, you have the right to request removal of content posted by you on our websites. Upon receipt of a fully completed removal request, we will use commercially reasonable efforts to remove content posted by you from our websites. Any such request does not ensure complete or comprehensive removal of your posted content. For example, your posted content may continue to appear on TMC’s websites if it has been reposted by others, independently posted by a third-party, was posted by you anonymously, or if you were compensated for providing the content.

Additionally, while TMC will remove the content you posted from our websites, it may continue to be stored on our servers (although it will not be visible to other users of our websites). You must complete the removal request form accurately and in its entirely in order for the request to be processed.

How to Provide a California Minor Removal Request

If you are a user under the age of 18 and reside in California, and you wish for your published content to be removed from TMC’s websites, please provide TMC’s Agent listed below with the following information in a written notice:

(1.) Confirmation that you are currently a legal resident of the state of California;
(2.) Confirmation that you are under the age of 18 by providing your birthday;
(3.) Describe the exact content that you are seeking to have removed (please provide a URL if possible);
(4.) Provide your full name; and
(5.) Provide your email address.

TMC’s designated Agent for California Minor Removal Requests can be reached as follows:

Service Provider: Training Management Corporation
Name of Agent of Request: Rita Pauls
By mail: 7 Roszel Road, Princeton, NJ 08540
By fax: (609) 524-9870
Email: rita.pauls@berlitz.de (please add “California Minor Removal Request” to the subject line)

Changes to this Policy

We 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 e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Privacy Shield

Training Management Corporation and its parent company Berlitz participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Training Management Corporation is committed to subjecting all personal data received from European Union (EU) member countries, 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/list]

Training Management Corporation is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Training Management Corporation complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Training Management Corporation is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Training Management Corporation may be required to disclose personal data in response to lawful requests by public authorities, including to meet 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 invoke binding arbitration when other dispute resolution procedures have been exhausted.

How Can You Contact Us?

If you have any questions or comments about this Policy, please select your country and use the Contact form. Complaints will be resolved internally in accordance with TMC’s complaints procedures.

California Residents

Residents of the State of California have the right to request a list of all third- parties to which we have disclosed certain information during the preceding year for the third-parties' direct marketing purposes.

However, it is our policy to neither disclose personal information, nor to sell such information to third-parties for direct marketing purposes.

This policy is effective as of November 30, 2016