PRIVACY POLICY

I. GENERAL

This Privacy Policy (“Policy”) is set forth and effective as of May 25, 2020 for Industrial Training International, Inc. (“ITI” or “we”, “us” or “our”). Your privacy is important to ITI. This privacy policy is intended to give you confidence in the privacy and security of the personal information (“Personal Information”) we obtain from you, whether you are interested in retaining our services, including: ITI Training, Consulting, E-Learning or VR Simulations (the “Services”), uploading information to our Training Solutions’ websites (the “Websites”), such as www.iti.com, www.riggingengineering.com, or www.lites.org downloading our applications, or are merely visiting our Websites. This Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information. This Policy is intended to meet privacy requirements in North America and Europe.

However, please note that we are not responsible in any way for any use of your Personal Information you provide to third-party applications or websites that may be accessed via the Services or Websites. We recommend that you review the privacy policy of any third-party applications or websites that you use.

II. COLLECTION OF PERSONAL INFORMATION

The types of Personal Information we may collect (directly from you or from third-party sources) and our privacy practices depend on the nature of the relationship you have with ITI and the requirements of applicable law. “Personal Information” is any information relating to an identified or identifiable natural person.

• When you use our Services or Websites, you may be asked for Personal Information such as your name, employer, email address, and telephone number.
• As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies, as described below.

We endeavor to collect only that information which is relevant for the purposes of offering the Services. Section IV highlights the ways we collect Personal Information and how we use it.

By providing such Personal Information, you consent to our using it in the manner described in this Policy.

III. USE OF SERVICES FEEDBACK

ITI will use services feedback, including course review comments, student experience information and other similar data (“Services Feedback”) submitted to our Websites or acquired following our Services. ITI may use such Services Feedback in any way, including, but not limited to, using, reproducing, publishing and/or distributing the Services Feedback for any purpose, commercial or otherwise, provided that such Services Feedback is stripped of all Personal Information. If ITI intends to use Services Feedback that identifies your name, or company, permission will be requested from you by an ITI representative prior to identification.

IV. USE OF PERSONAL INFORMATION

We acquire, hold and use Personal Information to allow us to process your Service requests, provide access to privileged areas of the Websites, send out E-Newsletters, personalize your visit to our Websites, personalize your use of our Services, and enable us to improve the Services and training solutions we offer.

Individuals who provide ITI with Personal Information, or whose Personal Information we obtain from third parties, may receive periodic emails, referral offers, newsletters, mailings, or phone calls from us with information on ITI’s Services. We offer the option to decline these communications at no cost to the individual by following the instructions set forth in Section VIII, below.

We may occasionally carry out market research and send you details of Services and opportunities that our team thinks may be of interest to you. If you do not wish to receive such information, we offer the option to decline these communications at no cost to the individual by following the instructions set forth in Section VIII, below.

V. DISCLOSURE OF CONTACT INFORMATION

We may provide your Personal Information about you to our support staff and technical team in order to administer any services and solutions provided to you by ITI

We will not disclose your Personal Information to any third party unless you have consented to such disclosure or where we are required to do so by law. Should you breach our terms and conditions, or if ITI is under a duty to disclose or share your contact data in order to comply with any legal obligation, we may disclose your Personal Information to a relevant authority. This may include exchanging information with other companies and organizations for the purposes of fraud protection. Any disclosure of any Personal Information will be strictly controlled and made fully in accordance with current applicable law.

VI. COOKIES; THIRD-PARTY SITES AND SOCIAL MEDIA PLATFORMS

Cookies are small data files that a website you visit may save on your computer, tablet or smartphone that usually include an anonymous unique identifier. Our Websites and those of our Services may use cookies for user authentication, keeping track of your preferences, promotional campaigns, tracking visitation and usage patterns. We may include small graphic images in our email correspondence and newsletters to determine whether the messages were opened and the links were viewed.

Third-party advertisers on websites linking to and from www.iti.com may also create and access cookies, which will be subject to their privacy policies – ITI accepts no responsibility or liability for the use of such third party cookies. If you do not wish for cookies to be placed on your computer, tablet or smartphone then they can be disabled via the web browser settings. Please note that permanently disabling cookies in your browser may hinder your use of our Websites and any Services, as well as other websites and digital services.

The Websites may contain links to other websites and other websites may reference or link to ITI’s Websites or other Services. These other domains and websites are not controlled by ITI, and ITI does not endorse or make any representations about any third-party websites or social media platforms.  We encourage the users of our Websites and Services to read the privacy policies of each and every website and application that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is solely at your own risk.

The Websites and our other Services may also contain links and interactive features with various social medial platforms. If you already use these platforms, their cookies may be set on your device when using our Website or our other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social medial platform or otherwise online, or that you share in an open forum, may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

VII. SECURITY

All security on our Websites is treated seriously. Where applicable, we undertake security steps, including use of SSL technology, through our host provider to protect data transmissions. However, this is not a guarantee that such data transmissions cannot be accessed, altered or deleted due to firewall or other security software failures.

We take steps to ensure that your information is treated securely and in accordance with this Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Websites or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Websites. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the Websites or sending an e-mail to you. You may have a legal right to receive this notice in writing.

If you have any further concerns about security, please email our team at info@iti.com.

VIII. OPT-OUT (RIGHT TO RESTRICT USE)

8.1 General

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to ITI’s use of your Personal Information, you may withdraw that consent at any time and opt-out to further use by contacting info@iti.com. We will delete record of your contact information within three business days of receipt of your withdrawal of consent. Even if you opt-out, we may still collect and use non-Personal Information regarding  your activities  on our Webites and/or  information  from the advertisements on third-party  websites  for non-interest  based  advertising  purposes,  such as to determine  the effectiveness  of the advertisements.

8.2 E-Mail and Telephone Communication

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or Services you have purchased. We may also send you certain communications regarding ITI and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to this Policy). We will provide opt-out notices to third parties who may contact you on our behalf in accordance with this Policy. While we will endeavor to ensure that you are removed from any such contact lists, we cannot guarantee that this will occur (for example, if your Information is provided to the third party through another advertiser whose communications you have elected to receive and not opted out).

We maintain telephone "do-not-call" and "do-not-mail" lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

8.3 Human Resource Data

With regard to Personal Information that ITI receives in connection with the employment relationship, ITI will use such Personal Information only for employment-related purposes as more fully described above. If ITI intends to use this Personal Information for any other purpose, ITI will notify the Individual and provide an opportunity to opt-out of such uses.

8.4 Do Not Track

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

8.5 Cookies and Interest-Based Advertising

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites.  These advertisements   provide a mechanism to opt-out of the advertising partners' use of this information for interest-based   advertising purposes.

IX. RIGHTS OF ACCESS, RECTIFICATION AND ERASURE

You may inquire as to whether ITI is using Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to info@iti.com or use any of the methods set out in this Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by ITI. Such requests will be processed in line with applicable laws. Whenever you withdraw your consent, you acknowledge and agree that this may have a negative influence on the quality of the Websites and/or the Services we provide. You further acknowledge and agree that ITI shall not be held liable with respect to any loss and/or damage to your Personal Information if you choose to withdraw consent.

Although ITI makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which ITI is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others' privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual's privacy in the case in question or where it is commercially proprietary. If ITI determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, ITI will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

If you believe that the information we have about you is incorrect, you are welcome to contact us so we can update it and keep your data accurate. Any Personal Information that is no longer needed for the purposes specified for retention in this Policy will be deleted. If at any point you wish for ITI to delete information about you, you can simply contact ITI at info@iti.com.

X. RETENTION

ITI retains the Personal Information we receive as described in this Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

XI. CHILDREN'S PRIVACY

We do not knowingly collect, maintain, or use Personal Information from children under 13 (and in certain jurisdictions under the age of 16) years of age, and no part of the Websites are directed to children under the age of 13 (and in certain jurisdictions under the age of 16). If you learn that your child has provided us with Personal Information without your consent, you may alert us at info@ITI.com. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child's Personal Information.

XII. INTERNATIONAL USERS

By using the Website, you will transfer data to the United States. By choosing to visit the Website, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained  in this Policy will be governed by the laws of the State of Washington and the exclusive venue and jurisdiction for the adjudication of any disputes arising in connection with ITI, the Services or the Websites will be in the state and federal courts residing in King County, Washington.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your Personal Information, you consent to any transfer and processing in accordance with this Policy.

XIII. REDRESS/COMPLIANCE AND ACCOUNTABILITY

If after reviewing this Policy, you would like to submit a request or you have any questions or privacy concerns, please send an e-mail to info@iti.com or contact us at:

ITI will address your concerns and attempt to resolve any privacy issues in a timely manner.

XIV. OTHER RIGHTS AND IMPORTANT INFORMATION

• Revision to the Privacy Policy. We may revise this Policy at any time, and in our sole and exclusive discretion, so review it periodically. If you continue to visit the Websites and use the Services made available to you after such changes have been made, you hereby provide your consent to the changes.
• Posting of Revised Privacy Policy. If there are any material changes to this Policy, ITI will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Policy periodically.
• New Uses of Personal Information.  Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the individual for the acquisition, holding or use of Personal Information is otherwise required by law or contract, ITI will endeavor to comply with the law or contract.

XV. CALIFORNIA PRIVACY RIGHTS

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. ITI only shares Personal Information with third parties for their own marketing purposes as described herein or as you may consent.