Table of Contents
- General Matters
- Data We Receive
- How We Use Your Data
- How We Share Information
- Data Retention
- Rights and Choices
- Other Important Information
1. General Matters
We at ISN Software Corporation and our subsidiaries (collectively, “ISN,” “we,” “us,” or “our”), respect your concerns about privacy and strive to provide an exceptional experience and service for registered users (“Users”) of the Empower mobile application (the “App”).
2. Data We Receive
A. Data You Provide To Us
To create an Account, you are required to provide your first and last name, email address, mobile number and ZIP code. You also may choose to provide us with your ISN-ID number to link the App with your employer.
You may choose to provide additional information to add to your profile within the App (e.g., training certificates or other credentials). As a reminder, you must not post or add data to your Account or profile that you would not want to be shared or publicly available. We do not want to gather from you, and you should not provide to us, any sensitive personal information.
We may obtain certain data from you when you interact with the App or provide, post or upload information through the App in connection with our Services, such as when you view trainings through the App, confirm or acknowledge certain information or documents through the App, fill out a form, respond to a survey, or submit other information to us through the App.
You are not required to provide, post or upload data; however, if you do not do so, it may limit your ability to engage with our Services.
We log usage data (including log-ins, device information and IP address) when you interact with our App, such as when you view or click on content (e.g., learning videos), perform a search, install or update the App, etc.
Cookies and Similar Technologies
Your Device and Location
When you use or exit the App (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your use. We also may obtain information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, IDs and/or ISP, or your mobile carrier). If you use the App, then your device will send us data about your location based on your phone settings. We will ask you to opt-in before we collect your precise geolocation location.
We gather information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a request, we track whether you have acted on it and may send you reminders.
B. Data From Third Parties
In addition to the personal information we collect from you or your device, we also may obtain information about you from third parties.
ISN operates ISNetworld (a contractor management platform) and may operate other platforms or services (collectively, “ISN Platforms”). ISN Platforms may house data about you that is acquired from or on behalf of your employer or from third-party data providers.
ISN Platform Data
You may download the App even if you are not currently connected to your employer using any ISN Platform. If you enter your ISN-ID in the App, you may be able to connect with your employer and link the App to your employer’s account on an ISN Platform in order for you to transmit or receive any data that relates to you (“Your ISN Platform Data”) or other information to or from such ISN Platform.
Your Persistent ISN Platform Data
Following the termination of your association with your employer’s account on an ISN Platform, you may retain in the App certain of Your ISN Platform Data associated with that employer’s account on the ISN Platform.
3. How We Use Your Data
1. Provide, support, personalize and develop our Services and the ISN Platforms.
2. Manage your account.
3. Verify your identity.
4. Assist in data analytics.
5. Operate, evaluate and improve our business.
6. Comply with and enforce applicable laws and regulations, industry standards, and contractual obligations, as well as our policies and terms and conditions.
We do not sell your personal information.
How we use your data will depend on which Services you use, how you use those Services and the choices you make in your settings, which are located in the “Profile” section of the App. We use data about you to provide and personalize our Services to you through the App and to provide our services to various users of ISN Platforms, so that our services can be more relevant and useful to you and others.
We do not sell your personal information, so we do not offer an opt out for such sales.
In the process of establishing an Account, we ask you whether we, Users and other ISN Platform users may contact you by email or SMS. You are not required to provide this consent, but not opting in will limit your use of the App and our Services to you.
We use Users’ data and content for invitations and communications promoting engagement, our Services and ISN Platforms.
Developing Services and Research
We use data to conduct research and development for our Services and ISN Platforms in order to provide you and others with a better, more intuitive and personalized experience, and drive growth and engagement on our Services and ISN Platforms.
We use data to research worksite and industry trends. We may publish or allow others to publish insights, presented as aggregated data.
We may use data (which can include your communications) to investigate, respond to and resolve complaints and other issues (e.g., bugs) regarding the Service and ISN Platform.
We may use your data to produce and share insights that do not identify you. For example, we may use your data and combine it with other User data to generate statistics about our Users and users of other ISN Platforms, their industries, their HSE, ESG and other statistics or other insights.
Security and Investigations
We may use your data (including your communications) for security purposes or to prevent or investigate possible fraud and other unlawful activity, violations of our User Agreement, and/or attempts to harm our Users or others.
We may combine data collected from you with other sources to help us improve our products, services, marketing, and communications, as well as to help expand and tailor our interactions with you. This includes combining personal information we obtain through the App with information we obtain through the ISN Platforms, as well as other sources, for the purposes described above. We may anonymize, de-identify, or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we specify at the time of collection.
4. How We Share Information
Profile and Uploaded Data
Your profile and the content you provide, post or upload to the App, ISNetworld or another ISN Platform may be visible to other Users of our Services and ISN Platforms. In particular, by linking the App with your employer, it and other ISN Platform users will have access to information in your profile or that is uploaded to ISNetworld or another ISN Platform.
We use service providers to help us provide our Services and to perform services on our behalf (such as maintenance, IT services and support, analysis and analytics, audit, payments, marketing, development, security, ID verification, and background and credit checks). We do not authorize these entities to use or disclose such information except as necessary to perform services on our behalf or comply with legal requirements.
We also may disclose personal information about you (1) if we are required or permitted to do so by applicable law, regulation, or legal process (such as a court order or subpoena); (2) to law enforcement authorities and other government officials to comply with a legitimate legal request; (3) when we believe disclosure is necessary to prevent physical harm or financial loss to ISN, our employees, customers, or the public as required or permitted by law; (4) to establish, exercise, or defend our legal rights; and (5) in connection with an investigation of suspected or actual fraud, illegal activity, security, or technical issues. We may attempt to notify Users about legal demands for their personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge any or all demands.
5. Data Retention
We generally retain your data in the App only so long as you keep your Account active or as otherwise needed to provide our Services. We describe below how we delete and retain your data following Account closure.
For data uploaded through the App and transferred to one or more ISN Platforms, we retain your data in the ISN Platforms in accordance with their data retention and privacy policies.
We generally delete information relating to closed Accounts that is housed in the App within 30 days of Account closure, except as noted below.
We retain your data in the App even after you have closed your Account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud, abuse and other unlawful or inappropriate activity, enforce our User Agreement, or fulfill and document your deletion, opt-out and cancellation requests. We may also retain de-identified information after your Account has been closed.
Information you have shared with others (e.g., by linking your Account with an ISN Platform) will remain visible within the relevant ISN Platform after you close your Account or delete such information from your Profile or the App. Further, we do not control data that others have copied out of our Services or ISN Platforms and retain elsewhere.
6. Rights and Choices
Subject to applicable law, we provide you choices about the collection, use and sharing of your data, from deleting or correcting data you include in your Profile to offering certain opt-outs and controls. We offer you certain settings to control and manage the personal information we have about you, which are located in the “Profile” section of the App.
For personal information that we have about you, you may have the following rights where provided by applicable law:
- Delete data: You can ask us to erase or delete your personal information from the App by canceling your Account. This deletion option is subject to retention considerations discussed above;
- Change or correct data: You can edit some of your personal information through your Account. You can also ask us to edit your data in certain cases, particularly if it is inaccurate; and
- Access your data: You can ask us for a copy of your personal information.
You may contact us using the contact information below, and we will consider your request in accordance with applicable laws. Residents in certain countries or regions may have additional rights under their laws.
7. Other Important Information
We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
Cross-Border Data Transfers
If you are located in the EU, United Kingdom (“UK”), or Switzerland, we will comply with legal requirements with respect to providing adequate protection for the transfer of personal information to recipients in countries outside of the EU, UK, or Switzerland that have not been recognized as providing an adequate level of data protection, to the extent such legal requirements are applicable to our processing of your personal information. In this event, we will implement appropriate safeguards, including as appropriate, by executing data transfer agreements based on the European Commission’s Standard Contractual Clauses.
Lawful Bases for Processing
Depending on the purposes for which personal information is used, and the context in which the information is obtained, we rely on one or more of the following legal bases, subject to applicable law:
- Performance of a contract or to take steps at your request prior to entering into a contract;
- Our legitimate business interests (which we can explain to you in further detail upon request by contacting us as indicated in the Contact Information section below);
- Compliance with a legal obligation; or
- Your consent to the processing of your personal information, which you can revoke at any time.
Where we process data based on consent, we will ask for your explicit consent. Where we rely on contract, we will ask in our User Agreement that you agree to the processing of personal information that is necessary for entering into or performance of the contract. We will rely on legitimate interests as a basis for data processing where the processing of your data is not overridden by your interests or fundamental rights and freedoms.
Where we rely on your consent to process personal information, you have the right to decline your consent or to withdraw your consent at any time by requesting deletion of your information from the App and closure of your Account; provided, however, that your data that has been transferred to an ISN Platform may, upon a withdrawal of consent, be deleted from such ISN Platform only through the process for deleting data that is in effect for the ISN Platform. If you have any questions about the lawful bases upon which we gather and use your personal information, you may contact our Data Protection Officer at firstname.lastname@example.org.
We currently do not share personal information with third parties for their direct marketing purposes without your permission.
If you have questions or complaints regarding this Policy, please contact ISN using the information on our Contact Us page. If contacting us does not resolve your complaint, you may have other options. For example, residents in certain countries and other regions may have the right to contact our Data Protection Officer at email@example.com or other rights under applicable laws.