311i Privacy Statement

Protecting the individual’s privacy on the Internet is crucial to the future of Internet-based business and the move toward a true Internet economy. We have created this Privacy Statement to demonstrate our firm commitment to the individual’s right to data protection and privacy. This Privacy Statement outlines how we handle information that can be used to directly or indirectly identify an individual (“Personal Data”).

A. General Information

When does this Privacy Statement apply? This Privacy Statement applies to Personal Data that you provide to 311i, and/ or its affiliates, or which is derived from the Personal Data as outlined below. The use of and any information that is gathered by cookies or other web tracking technologies is subject to the disclosures and options provided by the TrustArc Consent Manager which can be found on the relevant website.

Data Controller. The data controller of www.311institute.com is 311i Ltd., Bennett House, The Dean, Alresford, Hampshire. SO24 9BH. (“311i”). Where a registration form is presented on this website, the data controller may vary depending on the actual offering or the purpose of the data collection but it is in any case displayed on the individual registration form’s privacy statement. The 311i data protection officer can be contacted at (privacy@311institute.com).

What does 311i do with my Personal Data? 311i will process the Personal Data provided hereunder only as set out in this Privacy Statement. Further information can be found in Sections B. and C. below. Where the processing of your Personal Data is based on a statutory permission, you can find information on which Personal Data 311i is processing or using for which purposes in Section B below. Where consent for the processing of your Personal Data is required you can find further information in Section C. below.

 

Duration of processing of Personal Data. Where 311i is processing and using your Personal Data as permitted by law (see B. below) or under your consent (see C. below), 311i will store your Personal Data (i) only for as long as is required to fulfil the purposes set out below or (ii) until you object to 311i’s use of your Personal Data (where311i has a legitimate interest in using your Personal Data), or (iii) until you withdraw your consent (where you consented to311i using your Personal Data). However, where311i is required by mandatory law to retain your Personal Data longer or where your Personal Data is required for311i to assert or defend against legal claims,311i will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.

Why am I required to provide Personal Data? As a general principle, your granting of any consent and your provision of any Personal Data hereunder is entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide Personal Data. However, there are circumstances in which 311i cannot take action without certain Personal Data, for example because this Personal Data is required to process your orders or provide you with access to a web offering or newsletter. In these cases, it will unfortunately not be possible for 311i to provide you with what you request without the relevant Personal Data.

 

Where will my Personal Data be processed? As a global  company 311i has affiliates and third-party service providers within as well as outside of the European Economic Area (the “EEA”). As a consequence, whenever 311i is using or otherwise processing your Personal Data for the purposes set out in this Privacy Statement, 311i may transfer your Personal Data to countries outside of the EEA including to such countries in which a statutory level of data protection applies that is not comparable to the level of data protection within the EEA. Whenever such transfer occurs, it is based on the Standard Contractual Clauses (according to EU Commission Decision 87/2010/EC or any future replacement) in order to contractually provide that your Personal Data is subject to a level of data protection that applies within the EEA. You may obtain a redacted copy (from which commercial information and information that is not relevant has been removed) of such Standard Contractual Clauses by sending a request to privacy@311institute.com.

Data subjects’ rights. You can request from 311i at any time information about which Personal Data 311i processes about you and the correction or deletion of such Personal Data. Please note, however, that 311i can delete your Personal Data only if there is no statutory obligation or prevailing right of 311i to retain it. Kindly note that if you request that SAP delete your Personal Data, you will not be able to continue to use any 311i service that requires 311i’s use of your Personal Data.

If 311i uses your Personal Data based on your consent or to perform a contract with you, you may further request from 311i a copy of the Personal Data that you have provided to 311i. In this case, please contact the email address below and specify the information or processing activities to which your request relates, the format in which you would like this information, and whether the Personal Data is to be sent to you or another recipient. 311i will carefully consider your request and discuss with you how it can best fulfill it.

Furthermore, you can request from 311i that 311i restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data 311i has about you is incorrect, (but only for as long as 311i requires to check the accuracy of the relevant Personal Data), (ii) there is no legal basis for 311i processing your Personal Data and you demand that 311i restricts your Personal Data from further processing, (iii) 311i no longer requires your Personal Data but you claim that you require 311i to retain such data in order to claim or exercise legal rights or to defend against third party claims or (iv) in case you object to the processing of your Personal Data by 311i (based on 311i’s legitimate interest as further set out in B. below) for as long as it is required to review as to whether 311i has a prevailing interest or legal obligation in processing your Personal Data.

Right to lodge a complaint. If you believe that 311i is not processing your Personal Data in accordance with the requirements set out herein or applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which SAP has its registered seat.

Use of this website by children. This website is not intended for anyone under the age of 16 years. If you are younger than 16, you may not register with or use this website.

Links to other websites. This website may contain links to foreign (meaning non-311i Group companies) websites. 311i is not responsible for the privacy practices or the content of websites outside the 311i group of companies. Therefore, we recommend that you carefully read the privacy statements of such foreign sites.

B.  Where 311i uses My Personal Data based on the Law

In the following cases, 311i is permitted to process your Personal Data under the applicable data protection law.

Providing the requested goods or services. If you order goods or services from 311i, 311i will use the Personal Data that you enter into the order or registration form (usually (a subset of) your name, (email) address, telephone number, company name and address, your job title and role and, if payment is to be made to 311i, credit card number or bank details) only to process your order or to provide the requested goods or service. This may include taking the necessary steps prior to entering into the contract, responding to your related inquiries, and providing you with shipping and billing information and to process or provide customer feedback and support. This may also include conversation data that you may trigger via the chat functionalities on 311institute.com or other local 311i web presences, contact forms, emails, or telephone. In this Privacy Statement, “goods and services” includes (access to) 311i’s web services, offerings, contests, sweepstakes, other content, non-marketing related newsletters, whitepapers, tutorials, trainings and events.

If you participate in tutorials or trainings provided by 311i, 311i may also track your learning progress in order to make this information available to you. Furthermore, we communicate on a regular basis by email with users who subscribe to our services, and we may also communicate by phone to resolve customer complaints or investigate suspicious transactions. We may use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications, which are not marketing-related but merely required for the relevant business relationship. With regard to marketing-related types of communication (i.e. E-Mails and phone calls), 311i will (i) where legally required only provide you with such information after you have opted in and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us. You can opt out of these at any time by contacting us.

Ensuring compliance. 311i and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, 311i is required to take measures to prevent entities, organisations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through 311i’s websites or other delivery channels controlled by 311i. This may include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to 311i’s services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match.

Furthermore, you acknowledge that any information required to track your choices regarding the processing or use of your Personal Data or receipt of marketing materials (that is to say, depending on the country in which the relevant 311i group company operates, whether you have expressly consented to or opted out of receiving marketing materials) may be stored and exchanged between members of the 311i group as required to ensure compliance.

311i’s legitimate interest. Each of the use cases below constitutes a legitimate interest of 311i to process or use your Personal Data. If you do not agree with this approach, you may object against 311i’s processing or use of your Personal Data as set out below.

Questionnaires and surveys. 311i may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any Personal Data. If you nonetheless enter Personal Data in a questionnaire or survey, 311i may use such Personal Data to improve its products and services.

Creation of anonymised data sets. 311i may anonymise Personal Data provided under this Privacy Statement to create anonymised data sets, which will then be used to improve its and its affiliates’ products and services.

Recording of calls and chats for quality improvement purposes. In case of telephone calls or chat sessions, 311i may record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions in order to improve the quality of 311i’s services.

In order to keep you up-to-date/request feedback. Within an existing business relationship between you and 311i, 311i may inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars or events) which are similar or relate to such products and services you have already purchased or used from 311i. Furthermore, where you have attended a webinar, seminar or event of 311i or purchased products or services from 311i, 311i may contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product or service.

Right to object. You may object to 311i using Personal Data for the above purposes at any time by unsubscribing. If you do so, 311i will cease using your Personal Data for the above purposes (that is to say, under a legitimate interest set out above) and remove it from its systems unless 311i is permitted to use such Personal Data for another purpose set out in this Privacy Statement or 311i determines and demonstrates a compelling legitimate interest to continue processing your Personal Data.

C. Where 311i uses My Personal Data based on My Consent

In the following cases 311i will only use your Personal Data as further detailed below after you have granted your prior consent into the relevant processing operations. Therefore, each information about a processing operation with regard to Personal Data is linked to one consent statement in the Consent Resource Center. If you re-open this Privacy Statement after you have initially one or more consents granted you will not only see the information related to the consents you have granted but the full privacy statement.

News about 311i’s Products and Services. Subject to a respective provision and your consent, 311i may use your name, E-Mail and postal address, telephone number, job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with 311i (prior purchases, participation in webinars, seminars, or events or the use of (web) services – further details on this topic can be found in the TrustArc Consent Manager displayed on the relevant 311i website) in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about 311i’s software and services (including marketing-related newsletters) as well as events of 311i and in order to display relevant content on 311i’s websites. In connection with these marketing-related activities, 311i may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks’ data or the web offerings’ own data bases in order to display to you more relevant information.

Creating user profiles. 311i offers you the option to use its web offerings including forums, blogs, and networks linked to this website that require you to register and create a user profile. User profiles provide the option to display personal information about you to other users, including but not limited to your name, photo, social media accounts, postal or email address, or both, telephone number, personal interests, skills, and basic information about your company.

These profiles may relate to a single web offering of 311i and/or 311i affiliates. It is, however, always your choice which of these additional web offerings you use and your Personal Data is only forwarded to them once you initially access them. Kindly note that without your consent for SAP to create such user profiles 311i will not be in a position to offer such services to you where your consent is a statutory requirement that 311i can provide these services to you.

Within any web offering, beyond the mere provision of access your profile is used to personalise interaction with other users (for example, by way of messaging or follow functionality) and by 311i to foster the quality of communication and collaboration through such offerings and for 311i to provide gamification elements (gamification is the process of taking something that already exists, such as a website, an enterprise application, or an online community, and integrating game mechanics into it to motivate participation, engagement, and loyalty). To the greatest extent supported by the relevant web offering, you can use the functionality of the relevant web offering to determine which information you want to share.

Special categories of Personal Data. In connection with the registration for and provision of access to an event or seminar, 311i may ask for information about your health for the purpose of identifying and being considerate of individuals who have disabilities or special dietary requirements throughout the event. Any such use of information is based on the consent you grant hereunder.

Kindly note that if you do not provide any such information about disabilities or special dietary requirements, 311i will not be able to take any respective precautions.

Event profiling. If you register for an event, seminar, or webinar of 311i, 311i may share basic participant information (your name, company, and E-Mail address) with other participants of the same event, seminar, or webinar for the purpose of communication and the exchange of ideas.

Forwarding your Personal Data to other 311i companies. 311i may transfer your Personal Data to other entities in the 311i group. The current list of 311i group entities can be found here. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Section C. above.

Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder by unsubscribing. In case of withdrawal, 311i will not process Personal Data subject to this consent any longer unless legally required to do so. In case 311i is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal data by 311i up to the point in time of your withdrawal. Furthermore, if your use of an 311i offering requires your prior consent, 311i will not be (any longer) able to provide the relevant service (or services, if you revoke the consent for 311i to use your profile under the 311i Cloud Platform Identity Authentication Service for multiple 311i offerings), offer or event to you after your revocation.

D.  US Specific Provisions

Where 311i is subject to U.S. privacy requirements, the following also applies:

Do Not Track. Your browser may allow you to set a “Do not track” preference. Unless otherwise stated, our sites do not honor “Do not track” requests. However, you may elect not to accept cookies by changing the designated settings on your web browser or, where available, by way of the TrustArc Consent Manager if the relevant website contains a link to it. Cookies are small text files placed on your computer while visiting certain sites on the Internet used to identify your computer. Please note that if you do not accept cookies, you may not be able to use certain functions and features of our site. This site does not allow third parties to gather information about you over time and across sites.

Requirements to Protect Children’s Privacy. We do not intend for our websites or online services to be used by anyone under the age of 13. If you are a parent or guardian and believe we may have collected information about a child, please contact at privacy@311institute.com.

E. Russia Specific Provisions

The following applies to users who are resident in the Russian Federation:

The services hereunder are not intended for use by citizens of the Russian Federation who are resident in Russia. If you are a Russian citizen residing in Russia, you are hereby notified that any Personal Data that you input into the services will be solely at your own risk and responsibility, that you expressly agree that 311i may gather your Personal Data and will process this data in the United States and in other countries, and that you will not hold 311i accountable for any potential non-observance of legislation of the Russian Federation.

 

Revised and posted as of January 22, 2018

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