Werkey for Business Privacy Statement
This Werkey Business Privacy Statement was last updated on July 2, 2021.
In the course of providing Werkey Services to Companies and related services to its corporate Customers, non-profit and government organizations ("Customers"), Werkey will receive and have access to personal data of individual Users to which Customers grant access ("Users ”). For the purposes of this privacy statement, Customers are data controllers and Werkey is a data processor.
The processing of User data by Werkey and the security measures implemented to protect such data are detailed and governed by a written Agreement between Werkey and each of its Customers. As a data processor, Werkey will access, store and use the personal data of individual Users solely for the purpose of providing the Werkey Services for Companies to its Customers and will process the data as instructed by its Customers.
As data controllers, Customers decide which of their employees or other authorized personnel will have access to the Services. They do this by designating one or more Account Administrators or group Administrators ("Administrator") who have the ability to customize the Customer's account, manage individual User accounts, access the tool and related reporting features, access the Administrator tools and, when instructed by Customer, populate Customer's account with courses provided by Customer. Customers are solely responsible for establishing policies and ensuring compliance with all applicable laws and regulations relating to the collection of personal information relating to individual Users selected by Customers to access Werkey for Business services.
Werkey has no direct relationship with individual Users, who must contact Customers (their employer) for assistance with any requests or questions relating to the processing of their personal information.
For the avoidance of doubt, this Privacy Statement does not apply to :
- Any processing of data for marketing purposes of the ''Werkey for Business'' service to corporations and prospecting companies;
In the event that Werkey makes any material changes in the way it processes User data to provide its services to Customers, it will notify Customers.
List of Contents
- Information about Users collected and stored by Werkey
- Purpose of User Data Processing
- Cookies and other tracking technologies
- Sharing User Information with Subprocessors
1. Information about Users Collected and Stored by Werkey
- When a User is granted access to the Services by the Administrator, a User may set up an individual User account and Werkey will collect the information provided by the User or Administrator. Customer may customize the type of data requested to create an account, which may include the following:
- First name, last name, email address, telephone, workplace address and valid identification number;
- Photo, areas of interest, professional skills, goals and role (optionally provided by the User or client);
- Other personal data, as permitted by the Customer;
- A unique identification number is assigned by Werkey when creating a User account.
- Individual User account information can only be set as private. The information cannot be searched through search engines, or viewed by anyone on the Internet.
- Administrators can assign a User to a group membership in an instance of the virtual learning environment;
- Customers may choose to integrate with Werkey for Business a Single Sign On (SSO) identity provider to allow Users to log into User accounts without the need to disclose passwords to Werkey. In this case, Users may log in by providing their individual SSO credentials to the SSO identity provider, who will authenticate them and allow or deny access to the Customer's account. In this case, SSO identity providers share with Werkey a unique cookie ID and authentication “token” information to recognize the User as an authorized User by the Customer.
- At Customer's option, the Werkey for Business service may allow Administrators and Users to interact with others, including instructors, teaching assistants, other students and Customer, by posting reviews of a course, messaging or chatting with others, posting questions or answers , or posting other content. Such public or shared content is stored by Werkey and may be publicly available or viewed by others, including Administrators, Users or Instructors and Teaching Assistants, depending on where such content is posted.
- Werkey stores information related to Users' activities as they use and interact with Werkey for Business services, such as enrolled and viewed courses (and information related to those courses); interactions with instructors, teaching assistants, Administrators and other Users; and progress within a course; as well as responses, essays, and other items submitted by Users to satisfy course requirements. This information is linked to a User's unique account ID and is shared with Customers through Customer's account reporting tools or upon Customer's request.
- The Werkey for Business service allows Users to contact Werkey's support team for assistance or to report a problem, concern, potential abuse or other issues related to the Services or other Users. Werkey may collect and store the User's name, email address, location, operating system, IP address, as well as the User's activity on the platform and communications with the support team. Werkey may request additional information from Users to resolve any problem reported by a User or another User.
- When a User uses Werkey for Business services, Werkey collects and stores certain information by automated means:
- Technical information about the User's computer or wireless device, such as IP address, operating system type and version, unique device ID, browser, browser language, domain and other operating systems or platform information. This information is collected through the use of server log files and tracking technologies such as:
- Cookies, which are small files that websites send to a computer or wireless device to uniquely identify a browser or mobile device or to store information in a browser setting; and;
- Other tracking technologies (see below for more detailed information).
- IP addresses received from Users' browsers or devices may be used to determine Users' approximate location.
- If a Customer makes purchases by credit card, Werkey may collect certain data about the purchase (such as name and zip code) as needed to process the order. Customers must provide certain payment and billing information directly to Werkey's payment processing partners, including name, credit card information, billing address and zip code. For security, Werkey does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
2. Purpose of User Data Processing and Retention Period
Werkey processes the information collected about Users and Administrators for the purpose of providing Werkey for Companies services to its Clients, specifically:
- Provide, administer and facilitate access to Werkey Services for Companies, for Customers and Users, and manage the Customer's or User's account preferences;
- Comply with the Customer's instructions regarding Users' personal data;
- View and send email notifications to Users to:
- Respond to User questions or concerns;
- Make notifications to Users at the customer's request;
- Sending messages and administrative information to Users, including confirmation of account creation, course enrollment, course progress, and notifications of response instructions to User questions;
- Provide information to Users about the courses made available to Users, availability and new features of the Werkey for Business service; personalized course recommendations, which Users can cancel at any time;
- Sending push notifications to the User's wireless devices to provide updates and other relevant messages, which can be managed in the “options” or “settings” page of the mobile application;
- Allow communication between Users and instructors or teaching assistants;
- Request feedback to improve the User experience;
- Resolving User support requests or complaints.
2.1. Email preferences
Users can opt out of receiving non-transactional emails individually:
- following the unsubscribe instructions provided in the email communication; or
- manage the User's account email preferences. A customer may also instruct Werkey to configure email preference settings for all Users of a customer.
2.2. Retention of personal data
- Werkey will retain Users' data for as long as instructed by the customer;
- Werkey will delete some or all of the personal data relating to Users at the Customer's request;
- Werkey may retain aggregated or anonymized data as set out below.
2.3. Use of aggregated data
In addition, User data is aggregated with other User data of the Werkey Portal, to allow Werkey to improve its products and services and develop new products and services, including:
- Reviewing and analyzing the User's browser and wireless device technical information;
- Reviewing User activity on Werkey for Business and the Werkey Portal (for example, Werkey analyzes trends and User traffic and usage information to identify which courses are most popular);
- Facilitate the technical functioning of the Werkey Business Services and the Werkey Portal, including to troubleshoot and resolve issues, protect the Services and prevent fraud and abuse;
- Develop a custom course content recommendation engine
When User data is used for the above purposes, it is aggregated and/or anonymized so that no Users' personal data is processed.
3. Cookies and Other Tracking Technologies
Like many online platforms, Werkey and its analytics providers use server log files and automated data collection tools such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytical purposes to enable Werkey to understand how Users interact with Werkey for Business services. Werkey and its analytics providers may link the information collected through these means to the Users' unique account ID.
Cookies are small text files placed on a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about User activities. Werkey uses session cookies and persistent cookies:
- A session cookie is used to identify a particular visit to the Werkey for Business services and collect information about the interaction with the service. These cookies expire after a short period of time or when the User closes their browser after using the service. Werkey uses these cookies to identify a User during a single browsing session, such as when you connect to Werkey for Business services. This helps Werkey to improve the service, as well as to improve the Users' browsing experience.
- A persistent cookie will remain on the User's device for a certain period of time specified in the cookie. Werkey uses these cookies to identify and recognize a specific User over a long period of time. They allow Werkey to:
- Analyze the use of Werkey for Business services (for example, which links Users click on) in order to improve our offer;
- Test different versions of the services to see which specific features or content Users prefer to optimize Werkey for Business services;
- Provide a more personalized experience to Users with more relevant content and course recommendations and;
- Allow Users to log in more easily to use Werkey for Business services. Persistent cookies include:
- Preference cookies to remember information about a User's browser and configuration preferences, such as preferred language. Preference cookies make the User experience more functional and personalized;
- Authentication and security cookies to allow a User to log in or remain logged in and access the Service, to protect User accounts from fraudulent third-party logins, and to help detect, combat and protect against abuse or unauthorized use of User accounts;
- Functional cookies to improve the experience of using the Werkey for Business service, such as remembering the sound volume level selected by the User.
Werkey uses tracking technology to:
- Determine whether a particular page has been visited (for example, the landing page of an advertisement for Werkey for Business services that is displayed on third-party websites) or whether an email sent by Werkey has been opened or clicked on by a User;
- Personalize the learning experience of individual Users by recommending specific courses and other content.
3.1. User Preferences Regarding Cookies and Other Tracking Technologies
A User can configure their web browser to notify of the placement of new cookies, limit the type of cookies or reject cookies altogether. If enabled, a User may not be able to use some or all of the features of the Werkey for Business services (for example, may not be able to log in). General information about cookies and how to disable them can be found at www.allaboutcookies.org .
Various browsers may offer their own management tools for removing HTML5 LSOs. User can manage their cookie preferences via the cookie banner on Werkey websites, or send an email to firstname.lastname@example.org .
Most modern browsers offer the option to send a Do Not Track signal to websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard on how a website should respond to this signal and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the options described in this policy to manage the collection and use of information about you.
4. Sharing User Information with Subprocessors
In order to provide Werkey for Business services to its Customers, Werkey shares data concerning Users with various third-party service providers. These companies are contractually obligated to use User data exclusively as directed, for the purpose of providing services to Werkey:
- Companies and instructors of the Teach at Werkey program that upload courses to the Werkey Portal and make them available through Werkey's services for Companies, as well as their teaching assistants, who may receive User names and account profile information so that they can respond to questions and feedback from Users;
- Other Customer service providers as instructed by Customer;
- The Learning Environment Provider (LMS) is the company Epignosys, which relies on Amazon S3 to securely store eLearning content and uses Amazon CloudFront to distribute it. It also uses Sparkpost to handle transactional emails and some optional services like Stripe to handle payments when these are made directly in our learning environment;
- The Ecommerce platform of Portal Werkey, which may be open to Users of Werkey for Business, is Shopify, which uses its infrastructure in the United States, Canada, Ireland, Australia, India, United Kingdom, Singapore, Japan, Germany, New Zealand, Germany, China and Lithuania to sub-process the data of Customers who make purchases on the Werkey Portal;
- The payment processor of Portal Werkey, which may be open to Users of Werkey for Business, is Ebanx, which has infrastructure in several countries in the Americas;
- To perform some of its services, such as Single Sign On (SSO), Werkey rents servers from data centers operated by Hostgator located in Houston (Texas) and Provo (Utah), in the United States;
- Werkey's help center platform provider (Zendesk as of the effective date of this Privacy Statement) hosts and stores all communications between Administrators or Users and Werkey's support team. Zendesk is contractually obligated to store and process User-related data solely as directed by Werkey for the purpose of providing services to Werkey;
- Werkey shares User information with third-party companies such as Active Campaign, which perform e-mail services to allow it to send e-mail communications to Users and manage Users' e-mail preference settings;
- Werkey shares User information with third party companies that perform data analysis services to allow Werkey to better understand how Users use the service. These companies include Google Analytics. To prevent Google Analytics from collecting information for analysis, a User can install the Google Analytics opt-out browser by clicking here , and can also use Mixpanel opt-out by clicking here ;
- Any other sharing of User data is subject to Customer's consent and instructions.