Effective: 11 March 2022

This Privacy and Data Processing Policy (“Notice”) reflects our global privacy practices and standards as of the effective date.
Individual Rights | Your Personal Information | Keeping and Securing Your Personal Information | Sharing Your Personal Information | International Data Transfers

Who We Are

Well Times Systems (“Well Times Systems”) is a technology-powered solutions company headquartered at N. California Blvd., Suite 290, Walnut Creek, CA, USA.

Well Times Systems also operates through its subsidiaries in Canada Inc.TRUSTe Europe Ltd. in the UK, TRUSTe Web Services Technologies, Inc. in the Philippines, and TRUSTe LLC, in the USA. Because we have engineering, product, and support operations in the U.S., Canada, and the Philippines, most personal data will be accessed from these locations. Most information is hosted at Amazon Web Services in the U.S., but Cookie Consent Manager (and Consent Manager in general) is hosted at AWS in Ireland and we also offer an option to host platform data in Germany. In addition, through our remote work environment, we may have employees or contractors who access the data from other countries, such as Brazil, Australia, or the United Kingdom..

If you have a privacy question, you may contact the Well Times Systems privacy team and our Office of General Counsel at or by using this form. You may also contact us via telephone. Full contact information of our privacy team, including of our representatives where this is legally required, is available via this page. We appreciate the opportunity to address your questions and concerns.If you have concerns about how we handle your personal information, you have the right to make a complaint about us to the privacy regulator in your country, state, or province. For complaints under the GDPR, the TH GDPR or the CANADA,USA Data Privacy Act, please refer to this page. Most privacy regulators can be contacted online using the resources provided at https://globalprivacyassembly.org/participation-in-the-assembly/members-online/ More information is included under “International Data Transfers” and “Privacy Shield.”

Telephone:  +44 1387 896597

Fax :- +44 1387 8596356

Our Data Values At Well Times Systems, Privacy is our Business.

• Embedding privacy. We strive to help businesses embed privacy into their strategy and operations by providing simple, scalable, and intelligent solutions that help our customers continually manage privacy compliance and risk.

• Responsible use. We help to promote responsible data use and stewardship among businesses and suppliers around the world.

• Purpose driven. We only collect, use, and share the information needed to provide and operate our solutions and to help our customers meet their accountability and regulatory compliance needs.

• Always improving. We process data about the use of our solutions and the way we operate our own business in order to help us better understand the needs of our customers, prospects, and other stakeholders, and to continue to improve user experience, features, and functionality of our solutions.  

Individual Rights

Depending on your location, you may have basic rights under privacy and data protection laws related to the data we process about you. You may exercise those rights through the form accessible from the Individual Rights Manager button above, emailing us, or contacting us via telephone. These rights are free in most cases, and we will aim to respond to your request within 30 days or the specific timeframe required by the applicable laws. We will honor the requests you make related to your rights as the law allows, which means in some cases there may be legal or other official reasons that we may not be able to address the specific request you make related to your rights. The rights relate to:

• Access to the personal information we process about you

• Correction of inaccurate or incomplete personal information about you

• Deletion of personal information about you and Restrictions, temporarily or permanently, on our processing of some or all personal information about you  

• Transfer of personal information to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated

• Opt-out or object to our use of personal information about you where either
• our use is based on your consent or our legitimate interests, or you do not want us to share with third parties data related to cookies and similar technologies for website functionality or advertising purposes
• When you submit an individual rights request, you are consenting to us using your information to respond to your request. We will communicate with you via email in most cases. If you wish to withdraw your consent for us to respond to your request, you may do so via that email. Your consent includes that your request will come to the United States, which is where we are located. If you do not consent, we are unable to respond to your request.

Privacy Shield Inquiries & Complaints (data from the EEA or Switzerland)

If personal information about you was transferred by Well Times Systems from the EEA to the U.S. under the EU-US Privacy Shield, and you have an unresolved concern regarding personal information processing about you that we have not addressed to your satisfaction, please contact the EU authorities at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. Please also see information further below about our Privacy Shield involvement

If personal information about you is transferred by Well Times Systems from Switzerland to the U.S. pursuant to Privacy Shield, and you have an unresolved concern regarding personal information processing about you that we have not addressed to your satisfaction, please contact the Swiss FDPIC at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Under certain conditions, described more fully on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Your Personal Information See chart below followed by more information in expandable sections

What is personal information?

The data we process (collect, use, and share) about you depends on who you are and how we interact with you. Personal information is data that identifies you or that makes you identifiable. It includes data that could be used to identify, locate, track, or contact you. Listed below is a quick reference chart to indicate the activities in which we collect personal information on or from you. These activities may overlap, for example, a customer may visit our website. Below the chart, we provide more specific information on these activities

If you provide any personal information to us online, such as by filling out a form, attending a webinar, or through cookies (tracking technologies), we only use this information with your consent. You may withdraw your consent at any time by clicking the “unsubscribe” link in the email communications we send to you. You may also withdraw consent by exercising Your Rights as described above, including through our Individual Rights Manager and our Cookie Preferences Manager

Keeping and Securing Your Personal Information

We will keep personal information about you for as long as we provide solutions to you or your company; as long as you work for or with us; as long as we are addressing a concern, question, complaint, or request you have made to us; as applicable to our interactions with you; as long as the law requires us to do so; or for the time period we need to maintain the information, e.g., to respond to investigations or lawsuits. If we have a contract or other agreement with you or your company, we will follow the retention obligations of that agreement

We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements. We also may keep data about you for statistical analysis or research purposes

We take appropriate security measures to protect personal information against loss, misuse, and unauthorized access, alteration, disclosure or destruction. We also have implemented measures to maintain the ongoing confidentiality, integrity and availability of the systems and services that process personal information, and will restore the availability and access to data in a timely manner in the event of a physical or technical incident  
+1 800 603 6035

Fax: +1 800 889 9898

Sharing Your Personal Information

At Well Times Systems, we only share personal information in ways that we tell you about. We do not sell or rent personal information to third parties and we do not share personal information with third parties that are not owned by us, under our control or direction, or in a direct business relationship with us except as described in this Notice.

Service providers / Vendors We share personal information with service providers / vendors that help us with our business activities. Service providers support us in processing the types of personal information described above in the section “What personal information” and for the purposes described in the section “Why do we process personal information.” They only are authorized to process that information as necessary and as directed by us. Some of these providers qualify as “subprocessors” under the General Data Protection Regulation because they are used in the provision of services that our customer purchase

Business partnersWell Times Systems forms a variety of partnership relationships, to whom we may share your information legitimately under one of the reasons described in the Notice or receive information from them. We only permit partners to process your information as necessary and directed by us. In some cases, the partners may be contracted through Well Times Systems, such as customers who purchase education modules through one of our partners. In other cases, partners may share your information with us and their privacy notices will also apply

Required by law If we are required to disclose personal information as part of a legal process, we will take commercially reasonable steps to inform you as part of that process. We may also be required to disclose personal information in response to lawful requests by government authorities, including requests from national security agencies or law enforcement. Some of these requests may be by regulatory oversight agencies investigating a complaint where others may be by law enforcement looking for information
Safety, fraud prevention, government requests and protection of our rights are all reasons where we may share personal information where we believe in good faith it is necessary
Mergers, acquisitions, divestitures, or asset sales but only if the acquiring organization agrees to this Notice’s protections, where this is within our control. If we are under the control of a court, such as bankruptcy proceedings, we may not have full authority to ensure this protection
.  

International Data Transfer

Well Times Systems is headquartered in the United States and almost all data we process will be transferred to or accessed from the United States or through our subsidiaries in Canada or the Philippines. Customers have the option for their data to be hosted in the United States or Germany, and Cookie Consent Manager is hosted in Ireland. Customers should make sure that their notices reflect our transfer arrangements for their data subjects. Please see our Safeguards for more information on how we protect customer data in international transfers

This means that we may transfer, access, or store personal information about you outside of the European Economic Area (“EEA”), Switzerland, the United Kingdom, China, or another country that requires legal protections for international data transfer. When we do, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches

• We may transfer personal information to countries that have privacy laws that have been recognized by the country from which the data are transferred as providing similar protections for the data (“adequacy”)

• We may enter into written agreements, such as standard contractual clauses and other data transfer agreements, with recipients that require them to provide the same level of protection for the data  
• We may seek your consent for transfers of your personal information for specific purposes

• We may rely on other transfer mechanisms approved by authorities in the country from which the data are transferred

Privacy Shield

We participate in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and have self-certified to the U.S. Department of Commerce our adherence to the Privacy Shield Principles for all personal information received from countries in the European Economic Area and Switzerland in reliance on the Privacy Shield. We recognize that both Privacy Shield Frameworks are no longer recognized as a legal means to transfer personal data from the EU and Switzerland to the U.S., however Well Times Systems retains its certification as evidence of our commitment to providing appropriate safeguards. To learn more about Privacy Shield, visit the Privacy Shield website. Under Privacy Shield, we are responsible for the processing of personal information we receive and subsequently transfer to a third party acting for or on our behalf. We are liable for ensuring that the third parties we engage support our Privacy Shield commitments. The U.S. Federal Trade Commission has regulatory enforcement authority over our processing of personal information received or transferred pursuant to Privacy Shield. Well Times Systems commits to cooperate and comply with the advice of the regulatory authorities to whom you may raise a concern about our processing of personal information about you pursuant to Privacy Shield, including to the panel established by the EU authorities and the Swiss FDPIC. This is provided at no cost to you. Please see the section at the beginning about your rights.

Business Information and Links to Other Sites

Business information – In the course of using our solutions, we may ask you to provide business information related to the company where you work. Business information may include information about your company’s practices, policies, processes, and supporting documentation. This business information is stored on Well Times Systems systems, and we use it to provide the solutions you have contracted us to provide and in accordance with the terms and conditions set forth in agreements between Well Times Systems and your company

Changes to this Notice

We may make changes to this Notice from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. New laws and decisions occur relatively frequently, but may not impact this Notice. Any changes we make to the Notice in the future will be posted on this page, and where we change this Notice in substantive ways that also affect how we process personal information about you, where appropriate, we will notify you directly via email or other direct contact with you, and we also will indicate on our homepage that this Notice has changed. We will not notify you directly of changes that are minor or that involve formatting or rearranging. Change from November 1, 2021 to current version: formatting and additional clarification

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