eSkill Corporation (hereafter «eSkill» or «we») understands the power that the Internet holds for changing your life and making things easier for you. These benefits are at risk if people are concerned about their personal privacy. We are committed to providing you with an Internet experience that respects and protects your personal privacy choices and concerns.
1. Information gathered
Information can be collected from the users and the users’ test takers at several different points on our website.
1.1 General Information
In general, we gather information about all of our users collectively. We only use such information anonymously and in the aggregate. This information helps us determine what is most beneficial for our users, and how we can continually create a better overall experience for you.
We may share this information with our partners, but only in the aggregate, so that they too may understand how eSkill visitors use our site, and create a better overall experience for you, as well.
1.2 Personal Information
To sign up for eSkill’s services we ask to provide certain data including: name, address, phone number, email address, contact name and credit card information (note that this last information will not be stored by eSkill only transaction histories are kept).
eSkill administrator and test-taker functionalities requests the test takers to provide the following contact information: full name and email address (hereafter «test taker personal information»). This information is only used to contact the test taker when necessary and for storage purposes.
Note that for the test taker personal information received from Europe and covered by the Directive 95/46/EC or received from Switzerland, eSkill applies and adheres to the US-EU Safe Harbor Framework and to the US-Swiss Safe Harbor Framework, which both includes 7 Principles and 15 FAQs for the protection of this information. This only applies to information received after eSkill joined the Safe Harbor Frameworks by self-certification. eSkill will provide, upon request, the verification statement that needs to be done at least once a year (according to FAQ 7). This statement confirms that eSkill effectively adheres to the US-EU Safe Harbor or to the US-Swiss Safe Harbor, as the case might be, and that it has been duly implemented in its organization.
The following sections apply to both types of information collected by eSkill (general and personal information), unless otherwise specified.
2. Legal disclaimer
We do not disclose information to any outside parties for any reason whatsoever.
We can share aggregated general information with our partners solely for the purpose set out in Section 1.1.
We may disclose information when required by law, by a court or a governmental order or when such action is necessary in order to conform to the edicts of the law or comply with a legal process serviced on our website. In this case, we will promptly inform the user or test taker, as the case might be, of the potential disclosure or disclosure.
3. Information use
eSkill will not use the information for any other reasons than those disclosed in this document. The purposes of the data collected are described in Sections 1.1 and 1.2.
3.2 Exception for Troubleshooting
We may use your Internet protocol (I.P.) address to help diagnose problems with our server and to administer our website. An I.P. address is a set of numbers that is automatically assigned to your computer whenever you log on to your Internet service provider or through your company’s local area network (LAN) or wide area network (WAN).
4. Information saveguard and access
eSkill will record all information collected from the test takers for four years from the last use or last service provided. After this time period, the information will be erased from eSkill’s system.
At any time before the expiration date, the test taker can request the removal of his/her personal information, and eSkill will do so within a reasonable delay. This request should be made by email using the email address provided in the Contact Information section.
The test taker can also, at any time, request by email to have access to the personal information stored by eSkill. eSkill will reply, by the same means, to this request within a reasonable delay.
The test taker can reply back to submit any amendments or corrections to his/her personal information or to request the erasure of such information as mentioned in the paragraph above. eSkill will response to this request within a reasonable delay.
5.1 Security Policy
We operate secure data networks protected by industry standard firewalls and password protection. We have security measures in place, such as an organizational policy regarding security, to attempt to protect against the loss, misuse, and alteration of the user and test taker data under our control. eSkill perform a security audit twice a year and follows PCI security policy. The compliance to this last policy is also verified twice a year through monitoring.
5.2 Limited Access
Only certain employees have access to the information you provide us. We impose strict rules on our employees who have access either to the databases that store user and test taker information or to the servers that host our services. All our employees need to follow organizational security policies and all of them are also bound by a confidentiality agreement.
While we cannot guarantee that loss, misuse, disclosure or alteration to data will not occur, eSkill is taking reasonable precautions to prevent such unfortunate occurrences.
6. Enforcement of personal information
This section applies to Personal Information solely as described in Section 1.2.
6.1 Mechanisms for Complaint
After the test taker has exercise the rights under Sections 4.1 and 4.2 related to the modification and removal of his/her personal information, and either 1) the test taker, for whatever reasons, is not satisfied or 2) the test taker believes that eSkill didn’t fulfilled its obligation to act within a reasonable delay, the test taker can send a complaint to the firstname.lastname@example.org email address. eSkill will promptly reply to such a complaint and will attempt, in good faith, to resolve the complaint with the test taker if founded. Test takers can also address their complaint to BBB (Better Business Bureau), since eSkill is a BBB accredited business.
6.2 Mechanisms for Complaint Regarding US-EU Safe Harbor and US-Swiss Safe Harbor
When the US-EU Safe Harbor or US-Swiss Safe Harbor applies, the test taker must notify Eric J. Friedman, Chairman and CEO, directly by email at email@example.com of any complaint. When the complaint is founded, a serious and in good faith attempt will be deployed to resolve it. If this attempt fails, eSkill will actively cooperate with the European Union or Swiss’s data protection authorities in the resolution of any complaint and agrees to comply with any final decision, including any sanctions, taken by the authorities to close the dispute.
7.1 Email Links
eSkill provides email address links throughout its site, so that you can email us directly with any questions or comments you may have. eSkill reads all messages received and makes an effort to respond promptly. In addition to replying to your comment or inquiry, we may also file your email for future reference regarding improvements to our website.
7.2 Links to other websites
eSkill contains links to other websites. These sites have their own policies and practices with respect to online privacy, and eSkill cannot be responsible for the privacy practices or the content of these websites.
Many of the services available on our site provide you with the opportunity to opt out of receiving communications from our partners and from us. In addition, in the majority of our email communications, we will have instructions on how to unsubscribe so that you will not receive any future emails from us if you so choose.
Users who no longer wish to receive eSkill announcements may unsubscribe by sending an email to firstname.lastname@example.org with the word ‘REMOVE‘ in the Subject line.
9. Surveys & contests
From time to time, our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose the information.
Information requested may include contact information (such as name and email address), and demographic information (such as zip code). Contact information will be used to notify winners and award prizes.
Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.
10. Notification of changes
We will notify you directly if there is a material change in our privacy practices. We will take commercially reasonable measures to obtain written or active email consent from the user or test taker if we are going to be using the information in a manner different from that stated at the time of collection. We will also post the changes in our privacy statement 30 days prior to a change unless the change is to the user’s advantage.
11. Contact information