Echo360, Inc. and its related U.S. affiliated entities (collectively, “Echo360”) respect your privacy and are committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our website at https://echo360.com/ (“Site”) and tell you about your privacy rights and how the law protects you.
- Who we are and how to contact us.
- Your rights relating to your Personal Data.
- Marketing communications preferences.
- What Personal Data we collect.
- How we use your Personal Data and why.
- What happens when you do not provide necessary Personal Data?
- Who we share your Personal Data with.
- How we keep your Personal Data secure.
- How long we store your Personal Data.
- Our policy on children.
- Third party links.
Who we are.
Our address is: 11921 Freedom Drive, Suite 910, Reston, VA, USA 20190.
How to contact us.
You can contact us by:
- emailing: privacy@Echo360.com; or
- writing to: Echo360, Inc., Attn: Privacy Officer/Customer Information, 11955 Freedom Drive, Suite 700, Reston, VA 20190 USA.
Our Data Protection Officer
When you contact us, please describe in as much detail as possible the nature of your inquiry. We will investigate your inquiry promptly.
Our EU Representative
Our EU representative is: Blended Learning Consultancy Ltd. Our EU representative can be contacted directly by emailing them at the following address: EURep@Echo360.com.
Your rights relating to your Personal Data.
Your rights in connection with your Personal Data
Under certain circumstances, by law you have the right to:
- Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown here “Who We Are and How to Contact Us”.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority.
Marketing communications preferences.
You can ask us to stop sending you marketing messages at any time by following the update email preferences or unsubscribe links on any marketing message sent to you or by contacting us at any time using the contact details shown here “Who We Are and How to Contact Us”.
Please note that we may still find it necessary to communicate with you regarding your use of Site.
What Personal Data we collect.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.
It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).
However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
|Category of Personal Data collected||What this means|
|Identity Data||First name, surname, title|
|Contact Data||Your email address and telephone numbers.|
|Marketing and Communications Data||Your preferences in receiving marketing from us and your communication preferences.|
|Behavioural Data||Site access, page access, time spent on page, feature use and other patterns related to website flow and usage.|
|Technical Data||Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.|
|HR Data||Identity Data, government issued identification, work entitlement data (for purposes of verifying you are entitled to work in the country), your resume, education and career development data, performance appraisals, compensation elements, including, pay grade, salary, and pension fund contributions, bank account details, background records, and other relevant information necessary in the context of our current or potential employment relationship with you.|
No Special Categories of Personal Data
We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How we use your Personal Data and why.
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally we do not rely on your Consent as a legal basis for using your Personal Data.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
|Troubleshooting||To track issues that might be occurring on our systems.|
It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services.
|Marketing||· Identity Data|
· Contact Data
· Technical Data
· HR Data
|To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.|
We have a legitimate interest in providing you with updates on our Sites and related offers or information where you have purchased or shown interest in similar services from us.
|Human Resource Programs||To manage and administer our human resources programs, including employee communications, employee benefit programs, and other working relationships or arrangements, recruiting and hiring job applicants, assessing qualifications and performance, determining employee compensation and pay, performing background checks and references, managing terminations and transitions, employee training, employee health and security, and other general human resource purposes.|
We have a legitimate interest in administering our human resources programs, recruiting new applicants, and managing current employees for effective business operations.
Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).
In this case, we may have to stop you using our Site have with us but we will notify you if this is the case at the time.
Personal Data from Third Party Sources
We do not collect your Personal Data from third party sources.
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies:
- first party cookies, served directly by us to your computer or mobile device; and
- third party cookies, which are served by our partners or service providers on our Site.
Cookies we use
Our Site uses the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly.Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.|
|Analytics and Performance Cookies|
These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works.
You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
|Targeted and advertising cookies||These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.|
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.|
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.organd www.youronlinechoices.com.uk.
In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Who we share your Personal Data with.
The table below describes who we share your Personal Data with, what we share and why we share it.
|Recipients||Category(ies) of Personal Data we share.||Why we share it||Location(s)|
|Service Providers||· Identity Data|
· Contact Data
· Technical Data
· HR Data
Our service providers provide us with IT and system administration services and help us manage our customer relationships (including providing customer support, customer liaison etc).
To the extent third party service providers assist us in managing our human resources programs, we may provide them with HR Data as necessary for them to perform the services.
|· Within Europe|
· The United States
|Regulators and other authorities||· Identity Data|
· Contact Data
· HR Data
|Authorities may require reporting of processing activities in certain circumstances. We may disclose Personal Data if such disclosure is required by a valid and lawful order to a court or other governmental or public body.||· Within Europe|
· The United States
International Data transfers
Echo360 is a global organization headquartered in the United States and has legal entities, business functions, and systems in countries around the world. We share your Personal Data both with our affiliated companies within the Echo360 group and certain external third parties who are based outside the European Economic Area (“Europe”). Any processing of your Personal Data by these parties will involve the processing of your Personal Data outside of Europe. Other countries have privacy laws that are different from privacy laws in your country. Regardless of location, Echo360 handles Personal Data as described in this Policy. Where Personal Data is collected in the European Economic Area (“EEA”) and such Personal Data is transferred to a jurisdiction that is deemed to have inadequate protections, we have taken measures to ensure that such Personal Data is transferred and processed securely in accordance with this Policy. We rely on the European Commission-approved Standard Contractual Clauses (“SCCs”), which we enter into with our customers and partners, as a legal mechanism for transfers of Personal Data from the EEA. The SCCs are contractual commitments made between companies transferring Personal Data with respect to the privacy and security of such Personal Data. For more information about the SCCs, click here. We are also certified under the Privacy Shield Framework. For more information on our Privacy Shield compliance, please reference the section below.
Privacy Shield Framework
As described in the Privacy Shield Principles, Echo360 is accountable for Personal Data that it receives and subsequently transfers to third parties. If third parties that process Personal Data on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.
Privacy Officer/Customer Information
11921 Freedom Drive, Suite 910
Reston, VA 20190
Echo360 has further committed to refer unresolved Privacy Shield complaints to AAA an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit at http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of AAA are provided at no cost to you.
As further explained in the Privacy Shield Principles, binding arbitration before a Privacy Shield Panel will also be made available to you in order to address residual complaints not resolved by any other means. Echo360 is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
With respect to the collection of Data, Echo360 respects the national laws of the European Union (EU) country where the information was initially collected or processed prior to transfer. Echo360 commits to cooperate with the relevant EU Data Protection Authorities (“DPAs”) and shall comply with the advice given by such DPAs with regard to HR Data transferred from the EU in the context of the employment relationship, including, remedial or compensatory measures for the benefit of individuals affected by any non-compliance of the Privacy Shield Principles.
How we keep your Personal Data secure.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
Personal Data you provide to us resides on a secure server and is only accessible to selected employees and staff via password. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data.
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above “How we use your Personal Data and why.”, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
|Category of Personal Data||Retention period|
|Identity Data||For so long as retention is necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes.|
|Contact Data||For so long as retention is necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes.|
|Marketing and Communications Data||For so long as retention is necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes.|
Our policy on children.
This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.
Third party links.
Echo360, Inc., 2020