Privacy Policy

This privacy policy is effective as of 12/18/2018

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, as well as your rights in determining what we do with the information that we collect or hold about you. It also describes your choices regarding use, access and correction of your personal information.

This privacy policy applies to www.tmcorp.comwww.culturalnavigator.comhttp://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.

EU-U.S. and Swiss-U.S. 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 and the Swiss-U.S. Privacy Shield Framework. Training Management Corporation is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, 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 each 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 and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, 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 be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Data Protection Declaration

A. Responsible data processing body

The responsible body for the processing of personal data within the scope of this website and in accordance with the provisions of the General Data Protection Regulation (GDPR) is:

Training Management Corp. (TMC)
7 Roszel Road
Princeton, NJ 08540
+1 609 759 5490
Web: http://www.tmcorp.com/
Email: helpdesk@tmcorp.com
 

Berlitz Deutschland GmbH
Hahnstrasse 68-70
60528 Frankfurt am Main
Tel.: +49 (0)69 666 08 90
Web: www.berlitz.de
Email: info@berlitz.de

Our data protection officer is:

Henning Strahl, email: datenschutz@berlitz.de

In this data protection declaration, we would like to inform you about the extent to which your personal data (hereinafter referred to as "Data") is processed.

B. Data processing

We process Data for the operation of our website

The Data affected in such cases are listed below:

a) Log file

We record your visit to our webpages in a log file. In doing so, the following Data is processed: the name of each accessed webpage, the date and time of access, the data volume transferred, the browser type and version, the operating system used by you, the referrer URL (the previously visited website), your IP address and the access requesting provider. This is necessary in order to ensure website security. We process the Data accordingly on the basis of our legitimate interests pursuant to Art. 6 (1) f) GDPR.

Hosting

Within the scope of web hosting, all Data processed in connection with the operation of this website will be stored. This is necessary to ensure the operation of the website. We process the Data accordingly on the basis of our legitimate interests pursuant to Art. 6 (1) f) GDPR. We use the services of web hosting service providers, to whom we transfer the aforementioned data, for the operation of our website.

 

b) How to contact us

 

When contacting us, your Data (name, contact details, to the extent provided by you) and your message will be used solely for the purpose of the processing and handling of your request. The Data will be used for the processing of your request on the basis of Art. 6 (1) b) GDPR or Art. 6 (1) f) GDPR. For processing your contact requests, we work with service providers, to whom we transfer the aforementioned Data.

c) Customer account

When opening a customer account, you automatically consent to the storage of your contact details (name, email address, job function, and location) and your usage data (user name and password). In doing so, we are able to identify you as a customer and you are able to manage your orders. In this context, we will obtain the following consent from you:

“[  ] I would like to create a customer account. Please save my data for this purpose. I can withdraw my consent at any time by sending an email to helpdesk@tmcorp.com.”

Based on this consent, your Data will be processed pursuant to Art. 6 (1) a) GDPR.

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.

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.

d) Website analysis and marketing

We use “cookies” and smiliar technologies to enable the use of certain functions. Cookies are small data packages which are installed on your device and exchanged with other service providers. Some of the cookies used by us will be deleted as soon as you close your browser (“session cookies”). Other cookies remain on your device and will enable us to identify your browser again on your next visit (“persistent cookies”).

You can delete all cookies saved on your device and adjust the settings of your browser to prevent the installation of cookies.

In this case, you may have to readjust some settings each time you visit our website and accept the impairment of some of the provided functions.

We use cookies in connection with the following functionality:

aa) Google Analytics

We use Google Analytics which is a service of Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043 USA. For the provision of its services, Google uses certain cookies. The information on your use of this website (including your IP address) generated by the cookies, is transferred to a Google server in the USA, where they are stored. We use the stored information to analyse your use of our website, to prepare reports on website activities for the website operator and to provide additional services in connection with the use of the website. We process the Data obtained with your consent pursuant to Art.6 (1) a) GDPR. Under no circumstances will Google link your IP address to other Google data.

You can object to the collection of your Data at any time with future effect by applying the Google Analytics deactivation add-on for browsers at

http://tools.google.com/dlpage/gaoptout

Please also note the information on the use of data by Google available in the Google Partner network at:

https://www.google.com/intl/de/policies/privacy/partners/

www.google.de/privacy_ads.html

Google is certified at:

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

Additional information on data privacy is also available at: https://policies.google.com/privacy?hl=de&gl=de

C. Term of Data storage

We will only store personal Data for as long as is required for the purpose for which it is processed or until you withdraw your consent to the processing of such Data.  

Upon account expiration, users’ records will be permanently deleted from the system.

Where statutory retention obligations must be complied with, the storage period for certain Data may be up to 10 years, regardless of the processing purposes.

You may contact us at helpdesk@tmcorp.com 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 aggregate form. We will respond to your request within a reasonable timeframe.

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

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.

D. Your rights as the affected party

a) Right to information

On request, we will provide you with information on the personal Data stored on you, at any time and free of charge.

b) Correction, deletion, processing restrictions (blocking), objection

If you no longer consent to the storage of your personal Data or if your personal Data is no longer accurate, we will initiate the deletion or blocking of your Data at your request or ensure that your Data is updated accordingly (to the extent possible in accordance with the applicable laws and regulations). The same applies if you want your Data only to be processed subject to certain restrictions in the future.

c) Data portability

On request, we will provide you with your Data in a common, structured and machine-readable format so that you can transfer the Data to another competent party, where required.

d) Right of appeal

You have a right of appeal to your competent supervisory authority:

(https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html)

e) Right to withdraw consent with future effect

You can withdraw your given consent at any time with future effect. The withdrawal of your consent will, however, in no way affect the lawfulness of the processing of your Data before the time of withdrawal.

f) Restrictions

Data which cannot be used to identify the affected party, for example which has been anonymised for analysis purposes, are not affected by the above rights. The provision of information, deletion, blocking, correction or transfer of Data to another company may be possible if you provide us with additional information which enable an identification by us.

g) Exercise of your rights as an affected user

If you have any questions regarding your personal Data, the provision of information, corrections, blocking, objections or the deletion of Data or want your Data to be transferred to another company, please contact datenschutz@berlitz.de.

Changes to this Policy

We may update this Privacy Policy and its effective date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.