This policy was last updated on October 17, 2006.
RedHawk is committed to respecting your privacy and providing a secure online environment for:
- Web sites that RedHawk creates, configures, hosts and operates on behalf of its Customers ("Customer Web Sites"), and
- Our own corporate web site located at http://www.RedHawkEthics.com.
This Policy applies to all Personal Information RedHawk handles in connection with Customer Web Sites and our corporate web site located at http://www.RedHawkEthics.com. As used in this Policy, “Personal Information” means personally identifiable information, that is, information that identifies a particular person, such as first and last name, telephone number, Social Security number, date of birth, a home or other physical address and e-mail address or other online contact information. The term “Customer” includes Affiliates of the Customer and an “Affiliate” of a Customer means any other person directly or indirectly controlling or controlled by or under direct or indirect common control with the Customer. For these purposes, “control” means the power to direct management and policies, directly or indirectly.
This Policy discloses our privacy practices and expresses our commitment to keeping you informed of the Personal Information RedHawk collects and how it is used. RedHawk asks that you take time to read it carefully. RedHawk may update this Policy from time to time to reflect new uses, rules, regulations or technologies that impact your privacy. RedHawk recommends that Users review our Policy on a routine basis to view any changes.
Note to visitors outside the United States: This web site and the server(s) that make(s) this web site available are located in the United States. By using a Customer Web Site or our corporate web site, you consent to the transfer of personal information to, and the processing of personal information in, the U.S. In order to comply with European Union privacy laws in connection with personal information transferred to and processed in the U.S., RedHawk abides by the EU Safe Harbor framework as set forth by the U.S. Department of Commerce regarding collection, use, and retention of personal data from the European Union. Participation in the Safe Harbor is recognized as providing an adequate level of protection of privacy within the meaning of the EU Data Protection Directive.
Customer Web Sites
Collected Information and Its Use
RedHawk contracts with client companies ("Customers") to provide online knowledge, training and other services to their employees, contractors and other designated individuals ("Users" or "Students") on their behalf.
RedHawk typically provides its services via web sites that RedHawk creates, configures hosts and operates on behalf of the Customer. RedHawk needs to acquire limited Personal Information from either the Customer or User in order for the User to participate in a training program. RedHawk operates its programs and collects and uses information about Users at the direction of, and in accordance with, the instructions of RedHawk's Customers.
The Personal Information that RedHawk acquires includes, but may not be limited to: User name, e-mail address, unique User identification, associated Customer name, User department and location within the Customer’s organization, job title, password and supervisor information (“User Personal Information”). RedHawk does not collect any credit/debit card data, bank account data or other financial data concerning Users.
Course Tracking
When a User takes an online course RedHawk will save certain information about his or her progress in, and completion of, the courses on the Customer Web Site. This information may include: date started, time spent in the course, progress/completion data, bookmarks (to enable Users to navigate the web site/course without having to remember where they left off last) and test results (“Course Tracking Data”). Each User’s individual Course Tracking Data is linked to that User’s User Personal Information. “User Information” means User Personal Information and other information, such as Course Tracking Data, that may be linked to Users by RedHawk’s systems.
User Information is treated as confidential information of the Customer and is collected on behalf of, and in accordance with, each Customer’s instructions. RedHawk uses User Information to provide feedback to the Customer and to the User about a User's activity on a RedHawk-hosted Customer Web Site. For example, RedHawk may use User Information to send reminder e-mails and notifications to a User.
All information concerning a particular User that is in RedHawk's possession, including that User's User Information, is considered the proprietary information of the Customer with which the User is associated (i.e., the User's employer). RedHawk's arrangements with its Customers may require RedHawk to provide all such information directly to the Customer. If a User corresponds with RedHawk in connection with the training we offer on behalf of our Customer, RedHawk may keep a record of that correspondence. RedHawk may also forward correspondence to the Customer with which the User is associated.
RedHawk does not transfer any User Information concerning a User to any third party (other than RedHawk’s Customer) unless it is authorized to do so by the Customer with which the User is associated in connection with the services that RedHawk provides to that Customer, or unless we believe such action is necessary or permissible to: (a) comply with the law or legal process served on RedHawk; (b) protect and defend the rights or property of RedHawk; or (c) act in urgent circumstances to protect the personal safety of Users or members of the public.
RedHawk does not use User Information for marketing to third parties.
Limitation and Retention of User Information
We will use or retain User Information only in accordance with the terms of this Privacy Policy and only for so long as compliance with instructions from our Customers or with legal and tax obligations requires. Customers may engage RedHawk to provide data storage services for them, including storage of User Information, and these engagements may require data storage for various lengths of time.
Access and Updating of User Information
RedHawk is committed to ensuring that the User Information it receives is accurate. If you have questions or concerns about your User Information, please contact RedHawk. Please include your name, unique user identification (username/userID) and your company’s name with your correspondence. RedHawk may not be authorized to change some or all User Information concerning a User without the express authorization of the associated Customer. To protect User Information, we reserve the right to require additional forms of identification and to withhold the requested User Information until we are reasonably satisfied as to the identity and authority of the person making the request.
Cookies
A cookie is small data file containing information transferred between your browser and a web server. Cookies include session cookies, which are destroyed when your browser is closed, and persistent cookies, which may remain available after the browser is closed, until a specified expiration date.
RedHawk uses persistent cookies for its Customer Web Sites when a User’s browser is checked. The browser check is helps ensure that the User’s browser meets the minimal requirements necessary to take courses. An example of the type of information RedHawk stores in session cookies includes, but is not limited to, the URL of the Customer Web Site. RedHawk does not obtain Personal Information via cookies and does not link any data collected through cookies to any Personal Information.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to use features of the Customer Web Site that depend on cookies.
RedHawk Corporate Web Site
Collected Information and Its Use
Visitors to RedHawk’s public web site http://www.RedHawkEthics.com are not required to disclose any Personal Information. RedHawk may track activities of such visitors in order to refine and enhance our corporate web site and to collect marketing data. Data that is collected for these purposes is aggregated and is not stored in any personally identifiable form.
Visitor Information
If a visitor requests optional information such as a subscription to our newsletter, to see a demonstration or to evaluate RedHawk courses, Personal Information will be collected from the visitor for survey and marketing purposes and in order to respond to the visitor's request. Information may include: name, title, company, e-mail, phone number and other information. Visitor information will not be shared with, rented to or sold to any third parties.
Opt-out by Visitors
Visitors may opt-out of receiving our newsletter or other similar communications by sending an e-mail to privacy@redhawkethics.com. Indicate your preference to “unsubscribe,” and we will promptly remove you from our list. Please be sure to include your name and e-mail address in the e-mail. You may need to send separate e-mails if you are registered for more than one of our features or services. In addition, our newsletters and similar communications will include specific instructions on how to unsubscribe and you may unsubscribe at any time.
Retention of Visitor Information
We retain Personal Information from Visitors only for so long as is needed to fulfill their requests, support the services they have requested, or comply with legal and tax requirements. If there are no pending requests, orders or legal requirements for access to the Personal Information, we will destroy it after it is no longer necessary for the purposes for which it was collected.
Cookies
RedHawk uses cookies on its public corporate web site (http://www.RedHawkEthics.com) for record-keeping purposes and to remember certain information about Visitors. These cookies do not identify you as an individual.
General
Data Integrity & Data Security
Personal Information under our control is protected by means of appropriate physical, electronic, and procedural safeguards. Information collected through the operation of Customer Web Sites is stored on servers located in a secure environment. RedHawk limits the number of people who have physical access to RedHawk's database servers, utilizes electronic security systems, and uses password protections which help guard against unauthorized access. As of the date of this Privacy Policy, data transmitted to RedHawk's corporate web site is NOT encrypted in transmission; data transmitted to Customer Web Sites IS encrypted in transmission.
Only our employees and Customer-designated representatives who need the information to perform a specific job (for example, a system administrator) are given access to the information. Access to this information is protected by password. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee that our practices will prevent unauthorized attempts to access, use or disclose your Personal Information.
Aggregated Data
RedHawk collects or creates aggregated data about usage of our services. RedHawk owns this data and may share it with others. This aggregated data does not contain any Personal Information.
Links to Other Sites
RedHawk courses and web sites may contain links to additional information found on other sites. RedHawk is not responsible for the privacy policies, practices or content of other sites.
Business Transitions
In the event RedHawk goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. A notice of such a transition will be posted prominently on our corporate web site for at least 30 calendar days prior to the effectiveness of any such change.
Amendment and Acceptance of Privacy Policy Terms
RedHawk reserves the right to amend this Policy at any time. Any changes to this Policy will be posted to this web page as soon as reasonably possible and we will change the “As of” date at the top of this web page. If we make material changes to this Policy we will post a notice to that effect on the home pages of our corporate web site and each Customer Web Site. If RedHawk amends this Policy, the new Policy will indicate whether and how Users and Visitors can opt-out of changes affecting previously collected Personal Information that RedHawk retains. RedHawk suggests that you review this Policy on a periodic basis to view any changes. Use of the RedHawk’s corporate web site or any Customer Web Sites constitutes acceptance of this Policy.
BBB OnLine Privacy Program
RedHawk is a member of the BBB OnLine Privacy Program. BBB OnLine is an independent, non-profit organization whose mission is to build trust and confidence in the Internet by promoting the use of fair information practices. Because we want to demonstrate our commitment to your privacy, we have agreed to disclose our information practices and have our privacy practices reviewed for compliance by BBB OnLine.
Dispute Resolution
Any questions or concerns regarding the use or disclosure of personal information should be directed to the RedHawk Privacy Officer at the address below. RedHawk will investigate and attempt to resolve complaints and disputes regarding use or disclosure of personal information in accordance with the principles contained in this policy. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will serve as a liaison with RedHawk to resolve your concerns.
Additional Information and Complaints
If anyone has any questions about this Policy, the practices of, or his or her dealings with, any of RedHawk’s web sites, he or she should contact RedHawk at the following address:
Privacy Officer
RedHawk
615 Hope Road, Suite 2B
Eatontown, NJ 07724
privacy@redhawkethics.com
This policy is subject to change from time to time.