Client is responsible for processing the users’ personal data. By using the TrainTool domain for online training and testing as user, and/or supporting an online training and tests, as well as monitoring those as Coach, Administrator or Content Developer, on behalf of Client, personal data will be processed. This Privacy Statement describes how this works.
By agreeing to this privacy statement - and with it, the conditions for data processing - User gives explicit consent for this data processing. If User does not agree to this privacy statement, he or she is requested not to use the domain and notify Client.Full statement
1.1 Client is responsible for processing the users’ personal data. By using the TrainTool domain for online training and testing as user, and/or supporting an online training and tests, as well as monitoring those as Coach, Administrator or Content Developer, on behalf of Client, personal data will be processed. This Privacy Statement describes how this works.
1.2 By agreeing to this privacy statement - and with it, the conditions for data processing - User gives explicit consent for this data processing. If User does not agree to this privacy statement, he or she is requested not to use the domain and notify Client.
2.1 Administrator: an Administrator has all the rights to, within the domain, (i) create, edit or delete Users (in every role), (ii) compose and view reports on Users within the domain.
2.2 Coach: a Coach has been assigned to one or several Participants by Administrator. Dependent on how Administrator has set it up, Coach is allowed and able to monitor (observe), give feedback and assess a user’s training and/or test.
2.3 Content Developer: a Content Developer is allowed to make, edit and delete trainings within the domain.
2.4 Participant: a Participant is enrolled within Client to do an online training or test, and is allowed to use the domain.
2.5 Domain: The domain that has been made available for Client by TrainTool for online training and testing. This domain can be recognised by the URL (domain.traintool.com) and the lay-out. All the users’ data and their trainings can be consulted (only) within this domain.
2.6 User: a User is linked to the domain and is able to log in with an e-mail address and password, that have to be unique to this domain. User has one of following roles as minimum and all of the following roles as maximum: Participant, Coach, Administrator and Content Developer.
2.7 Privacy statement: this privacy statement.
2.8 Client: the organisation which has entered into a commercial contract with TrainTool B.V. to use TrainTool for its users.
3.1 Client, mediated by TrainTool, collects personal data of User that has been issued by that particular User in the context of an online training or test as User, and/or support of an online training and test, as well as monitoring as Coach, Administrator or Content Developer. This collection occurs when, for example:
3.1.1 Administrator makes an account for User, which is only allowed for Administrator for the benefit of Client, and authorises access to the domain for that particular User as Participant, Coach, Administrator and/or Content Developer;
3.1.2 User enrolls him or herself and/or participates in a training and/or test;
3.1.3 Participant shares camera recordings (by webcam or mobile camera) and/or audio recordings of an online training and/or test with his or her Coach or feedback group;
3.1.4 Participant asks his or her Coach or feedback group for feedback, or receives feedback from his or her coach or feedback group;
3.1.5 Participant asks his or her Coach for assessment, or receives assessment from his or her Coach;
3.1.6 Participant gives feedback to another Participant in his or her feedback group;
3.1.7 User asks TrainTool for support in using the domain;
3.1.8 Administrator of the domain asks for a report on the participation, progress and performance by the Participant concerning an online training and test.
3.2 The issued personal data that are processed by TrainTool, commissioned by Client, (and are issued by oneself or concerning oneself by the Clients Administrator or other Users) are:
3.2.1 data that need to be issued to use the Domain as User in order to do an online training and/or test, which are: (a) first and last name, (b) e-mail address, (c) personal password, (d) name of employer and/or training bureau, as well as position and location of employer, (e) name of the training(s), corresponding feedback group, Coach, Administrator and Content Developer, (f) camera footage or audio recordings (of a training that has been undertaken and saved by User), (g) information about the participation, progress and performance of an online training and test, like (i) issued answers on training questions, (ii) time use, (iii) extent and manner of feedback given to peers, as well as (iv) feedback and assessment issued by Coach.
3.2.2 data that may be issued to use the Domain as user in order to do an online training and test by issuing these data actively within their own online profile, which are, (a) phone number and (b) photograph.
3.3 The issued personal data are only processed by TrainTool, commissioned by Client, in order to execute its service on behalf of the Client, being: developing, facilitating, maintaining and optimising an online training and test platform for the Participant’s skills, as well as supporting the Participant’s use of that platform. More specifically, a focus on the practicing of soft skills by Participant with feedback from Coach and other Participants from his or her feedback group as well as making the level of the Participant (on an individual, group, or corporate level or anonymised for the corporate sector) transparent through reports.
4. Report (n/a)
5. Minors (n/a)
6. Sharing by participants
6.1 Participant can, during participation in an online training and test within the Domain, decide to share the (intermediate) results of an online training and test, like camera footage of an online training and test that have been undertaken and saved by User, as well as answers to other quesions or exercises, with someone in his or her feedback group, Coach, Administrator or TrainTool for technical support. This issued information can be viewed by these third parties. Those who choose to share particular information, should be aware that that information can be used by the third party in other unknown ways. This is beyond TrainTool’s responsibilities.
6.2 Participant is able to view issued results of an online training and test of other Participants if another Participant has explicitly shared them in order to receive feedback. Participant will not use these results and any other connected information in any other way than to give feedback within the domain. Other usage within the Domain or outside of the Domain is not allowed
7.1 Client has enabled TrainTool as editor for the purposes explained in this Privacy Statement under 3.3 and 3.4, with whom Client has agreed that TrainTool offers guarantees concerning technical and organisational security measures concerning the processing.
7.2 TrainTool uses cloudcomputing to execute its service to Client, where it engages (sub)editors for the encrypted storage of personal data of Users on servers within the European Union, with whom an agreement was made. This agreement also offers enough guarantees for technical and organisational security measures concerning the processing
7.3 TrainTool nor Client will issue the Users’ personal data for other purposes, except when the User has agreed to this, when it is necessary for TrainTool’s execution of its service, like issuing data to an external Coach, on the basis of a legal regulation or in an emergency, as long as this is of importance for the User, according to the reasonable judgement of Client.
8.1 TrainTool has, on behalf of Client, taken fitting technical and organisational measures to protect the Users’ issued and collected personal data against loss or unauthorized processing, including access to the Domain via an individual login based on a unique e-mail address and password as well as via secured SSL connections. Despite the fact that TrainTool, on behalf of Client, has taken and will take fitting security measures, there are risks linked to the processing of personal data on the internet, that are unfortunately inherent to internet use in social traffic.
9. Retention period
9.1 TrainTool does not retain the Users’ personal data within the Domain any longer than necessary for the execution of its service. The User’s personal data are deleted when TrainTool is ordered to do so by Client, for example, after Participant’s employment with Client has been ended. However, at maximum twelve months after the first enrollment for an online training or test, the User’s personal data are blocked and cannot be consulted by the particular Participant and his or her Coach, Administrator and/or Content Developer.
10. Inspection and correction
10.1 The User is allowed to view his or her collected personal data on the basis of the law of protection of personal information and, if necessary, to edit, add or delete them. In order to do so, one can consult his or her own profile within the Domain, as well as sending a request to Client.
11. Cookies (general)
11.1 TrainTool uses ‘cookies’ in order to execute its service for Client. Cookies are small text files that are saved by a computer if the Domain is visited. The cookie remembers what the User has filled in on the Domain for a next visit, like the chosen language, so that the content of the Domain can be specified to the specific User and therefore it is not necessary to fill in those personal data again.