SAI GLOBAL COMPLIANCE WEBSITE PRIVACY STATEMENT
(FROM POSTING TO 14 JULY 2014)

Compliance (Americas) Privacy Policy

Compliance and Ethics Learning Solutions Corporation, previously operating as Midi, now owned by SAI Global Ltd., and operating as part of the SAI Global Compliance Division ("SAI Global Compliance", "we", "us" or "our") is committed to respecting your privacy and providing a secure online environment to support your learning and development on websites that SAI Global Compliance creates and hosts on behalf of its Customers ("Customer Learning Sites"), and on our own corporate website. This Privacy Policy discloses our privacy practices and expresses our commitment to keeping you informed about the information we collect and how it is used. This Policy applies to all personal information we handle in connection with Customer Learning Sites and our corporate website.

SAI Global Compliance abides by the EU Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use and retention of data from the European Union.

Collected Information and Its Use


Customer Learning Sites

SAI Global Compliance contracts with client companies or organizations ("Customers") to provide training products, services and information to their employees, contractors and other designated individuals ("Users" or "Students") on their behalf.

SAI Global Compliance needs to acquire limited personal information from either the Customer or Student in order for the Student to participate in training or a related program. This information may include but may not be limited to: Student name; e-mail address; unique Student identification; department; job title; password and supervisor information. This information is used to enroll Students in appropriate course(s) and to direct them to information as requested by the Customer. Information is also collected on the Student's progress. This information may include: date started; time spent in a course; progress/completion data and test results. Student information is treated as confidential information of the Customer and is collected on behalf of and in accordance with their instructions. At the request of the Customer, SAI Global Compliance may use this information to contact the Student and send notifications, reminders and completion certificates.

Student information is collected on behalf of and shared with the Customer. SAI Global Compliance does not use Student information for marketing purposes. SAI Global Compliance discloses Student information only to third parties whose services are required to facilitate operation of the Customer Learning Sites, and the information is used only for the purpose for which it was originally collected. SAI Global Compliance does not disclose Student information to any other third parties unless expressly directed by the Customer or a court of law.

In an effort to continually improve its offerings and customer service, SAI Global Compliance examines aggregate data, including (but not limited to) number of users, number of users completing courses, length of time spent with courses, etc. SAI Global Compliance may include Customer data when it compiles and uses this data. Unless it receives prior written approval from the Customer, however, SAI Global Compliance will not release any data identifiable to the Customer.


SAI Global Compliance Corporate Website

Visitors to SAI Global Compliance's public website www.saiglobal.com/compliance are not required to disclose any personal information. We may track activities of visitors in order to refine and enhance our website and to collect marketing data. If a visitor elects to subscribe to a newsletter, view a Webcast or evaluate SAI Global Compliance courses, personal information will be collected from the visitor for survey and marketing purposes. 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.


Security

Student information under our control is protected from unauthorized access, alteration, misuse and loss. Information on Customer Learning Sites is stored on servers located in a secure environment that uses a firewall and a variety of other advanced security technology to discourage interference or access from outside intruders. 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.


Your Information

If you have questions or concerns about your personal information, please contact SAI Global Compliance. Please include your name and student ID with your correspondence. We cannot change Customer proprietary information supplied to us without the express authorization of the Customer. 


Cookies

A cookie is a 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. SAI Global Compliance uses session cookies to enable its corporate website and Customer Learning Sites to function as designed. Examples of the types of information SAI Global Compliance stores in session cookies include but are not limited to your student ID, which course you are viewing, and which parts of the course you have viewed. Depending on how our Customer has chosen to deliver courses to you, certain information may be stored in persistent cookies; this information is limited to a numeric Customer code and information enabling you to resume a course where you left off. 


Links to Other Sites

SAI Global Compliance courses and websites may contain links to additional information found on other sites. SAI Global Compliance is not responsible for the privacy policies, practices or content of other sites. We suggest that you review the privacy policy of each site you visit.


Acceptance of Privacy Policy Terms

SAI Global Compliance reserves the right to amend this policy at any time. Any changes to this policy will be posted to this page as soon as reasonably possible. If we amend the policy, the new policy will apply to personal information previously collected. We suggest that you review this policy on a periodic basis to view any changes. Use of the SAI Global Compliance corporate website or any Customer Learning Sites constitutes acceptance of this policy.


Dispute Resolution

Any questions or concerns regarding the use or disclosure of personal information should be directed to the SAI Global Compliance Law Department at the address below. SAI Global Compliance 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. SAI Global Compliance has also agreed to participate in the dispute resolution procedures of the European Data Protection Authorities to resolve disputes pursuant to the Safe Harbor principles.

Additional Information

If you have any questions about this Privacy Policy, the practices of any SAI Global Compliance site or dealings with SAI Global Compliance, please contact us at the following address:


SAI Global 
101 Morgan Lane Suite 301
Plainsboro, NJ 08536
privacyofficer.compliance@saiglobal.com