PRIVACY AND COOKIES POLICY

NCS Pearson, Inc. respects your privacy and has adopted this Privacy and Cookies Policy for the Pearson VUE Business Group described below (hereinafter “Privacy Policy”). Pearson VUE is a business of NCS Pearson, Inc. This Privacy Policy is global in nature and describes our data protection practices and the types of personal information that we may receive or collect from you on behalf of certification, credentialing, licensure, regulatory, and academic admission test sponsors. This Privacy Policy is applicable to those: individuals who desire to access, manage, publish, and provide their current credential status to their designated and authorized third parties (for example employers and background checking firms); users of websites and web pages that provide a link to this Privacy Policy (collectively this “Site(s)”); users of our products and services; and individuals purchasing study aides, books, e-books, tests, practice tests, vouchers and our other products and services available on Pearson VUE’s Site. In addition, this Privacy Policy describes your rights and responsibilities, our rights and responsibilities, how we use the information we collect or receive; with whom we share the information with; the measures we take to protect the security of personal information from loss, misuse and unauthorized access, the choices you can make about providing your personal information to us as it relates to your certification, credentialing, licensure, regulatory, and academic admission testing experience; and how you can contact us. All references to ‘our’, ‘us’, or ‘we’, in this Privacy Policy and within the opt-in notice are deemed to refer to the Pearson VUE Business Group, which for purposes of this Privacy Policy includes, Pearson VUE, Pearson Credential Management, and the Certiport businesses of NCS Pearson, Inc. as appropriate.

The rights and responsibilities described in our Privacy Policy do not cover third party websites that may be linked to our Site(s) or referred to on this Site(s). These third party websites have their own privacy policies and we encourage you to read and review them.

This Privacy Policy explains:

YOUR RIGHTS & RESPONSIBILITIES

You agree that by visiting and/or providing, transmitting, or having another party you have authorized provide or transmit your personal information to us on any of our Sites, you are accepting the practices described in this Privacy Policy and any updates made to this Privacy Policy. It is your responsibility to read this Privacy Policy and check for updates on a regular basis. By continuing to use our Site, products or services after such updates have been made you are agreeing to be bound by any changes to this Privacy Policy.

You are never required to provide us with your personal information. If you do not agree to this Privacy Policy, please do not provide, transmit or allow an authorized third party to provide or transmit your personal information to us; however, if you decide to not provide to us your personal information it may affect our ability to allow you to register, schedule, and take a test administered and delivered by us on behalf of the test program sponsor; or to provide to you any other products or services offered.

You agree that we may collect or receive, use, process, disclose, transfer and retain your personal information as described herein. This Privacy Policy governs your use of any and all of our Sites our testing services, and in purchasing our products and services in general. We will use your personal information only for the purposes set forth herein.

As the subject of the personal information collected, you have a right to know what personal information we hold about you. You may access and correct the personal information you have submitted by contacting a Pearson VUE customer service representative. To determine the correct Pearson VUE customer representative click on this link Pearson VUE Start here: select your program and search for the testing program’s name. We will respond to access requests within a reasonable amount of time in accordance with state and national laws and requirements.

If you have concerns with these Rights and Responsibilities or our compliance with them, click on HOW TO CONTACT US, for more information.

OUR RIGHTS & RESPONSIBILITIES

We will provide you access to these Rights and Responsibilities and any subsequent updates.

We encourage you to periodically review this Privacy Policy to learn more about our information practices as they change over time. We reserve the right to update this Privacy Policy periodically, without notice. A change in the effective date will indicate that the Privacy Policy has been updated. Any changes to our Privacy Policy will become effective upon posting of the revised Privacy Policy on our Site(s). Your use of our Site(s), and any of our products and services following such changes constitutes your acceptance of the revised Privacy Policy then in effect.

COMPLIANCE WITH THE EU-U.S. PRIVACY SHIELD FRAMEWORK PRINCIPLES AND THE U.S.-SWIS SAFE HARBOR FRAMEWORK PRINCIPLES

EU-U.S. Privacy Shield Framework

We are dedicated to providing privacy protection as defined by European Community laws for the handling of personal information received from individuals in the European Union and its Member States. The Pearson VUE Business Group complies with the EU-US Privacy Shield Framework requirements as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and its Member States to the United States. We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. To learn more about the EU-U.S. Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov. Unless we provide specific notice and obtain your consent, we do not collect or process any sensitive information, as defined by the Privacy Shield Principles.

The Pearson VUE Business Group is responsible for the processing of personal information received under the Privacy Shield Framework and subsequently transfer to a third party acting as an agent on our behalf.

We comply with the Privacy Shield Principles for all onward transfers of personal data from the European Union and its Member States.

In compliance with the EU-US Privacy Shield Principles we are committed to resolving complaints about our collection and use of your personal information. Click on Resolution of Concerns for more detailed information.

Additionally, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

U.S.-Swiss Safe Harbor Framework

The Pearson VUE Business Group complies with the U.S.-Swiss Safe Harbor Framework requirements as set forth by the U.S. Department of Commerce regarding the collection, processing, and retention of personal information from Switzerland. We have certified that we adhere to the Safe Harbor Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access, and Enforcement. To learn more about the U.S.-Swiss Safe Harbor and to view our certification page, click on Welcome to the U.S-Swiss.

Unless we provide specific notice and obtain your consent, we do not collect or process any sensitive information, as defined by the Safe Harbor Principles. The data we collect will only be used for providing to you your requested products or services or for other purposes for which you have given your consent, except where otherwise provided by law.

CERTIFICATION, LICENSURE, AND ACADEMIC ADMISSION TEST SERVICES

Description of Certification, Licensure, and Academic Admission Test Services.

We provide testing services as a service provider on behalf of test sponsors (that act as an autonomous data controller) and we provide testing services on behalf of ourselves. The test sponsor is the company or organization that offers certification, licensure, or academic admission testing and controls the test(s) that must be taken to secure such certification, credentialing, licensure, or academic admission. We collect or receive personal information from certification, licensure, and academic admission testing candidates on behalf of the test sponsor. We use this personal information in order to perform the testing services related to the administration and delivery of certification, licensure, and academic admission testing on behalf of the test sponsor. The information we may collect or receive includes, but is not limited to, your test registration, incident resolution (such as fraud prevention) collection of payment for testing services you’ve requested, your test results of such testing, and communicating with you about certification, licensure, and academic admission testing. Providing your personal information is voluntary, but maybe necessary if you wish to receive certification, licensure, or academic admission testing. We will handle and treat all personal information collected and received by us in connection with certification, licensure, and academic admission test registration and administration in the manner as described in this Privacy Policy. For more information about how the test sponsor may collect and use your personal information we encourage you to review the test sponsor’s privacy policy.

Personal Information Collected for Certification, Licensure, and Academic Admission Test Services

The personal information that we collect or receive in registering a candidate (“you”) for certification, licensure, or academic admission testing services include: name, address, email address, phone number, fax number, credit/debit card information, company and title. We may also collect or receive the following additional information at registration or in the testing process, as necessary or appropriate, including, but not limited to: language, date of birth, social security number, sponsor identification number, employment information, previous examination history, education information, and source of financing for the test. For candidate verification and identification purposes, we may collect all or part of a government-issued identification number and mother’s maiden name.

At the test center, depending upon the test sponsor and/or test security requirements, we may collect your signature, photographic image, a copy of your photo identification, fingerprint and/or palm vein image digitally (for the purposes of identity verification and to protect the security and integrity of the test) and you may be audio- and video-taped while taking the test. We may also collect your fingerprint and/or palm vein pattern when your ID does not meet the requirements of identity verification. Finally, when a certification, licensure, or academic admission test is administered to you, we may collect and score your test responses and then derive a test score and generate a report about your certification, credentialing, licensure, or academic admission test results.

In the event that you submit a request for an accommodation for your certification, licensure or academic admission test, you may be asked to submit health information records in compliance with your test sponsor’s requirements, including but not limited to, documentation from your physician evidencing your need for the accommodations. We will work with the test sponsor to evaluate your eligibility for an accommodation and if an accommodation is granted we will implement an acceptable accommodation solution.

Independent Testing Centers

Certain certification, credentialing, licensure, and academic admission tests are administered through independent authorized testing centers. These authorized testing centers are required to use any data collected in compliance with this Privacy Policy. If you have unaddressed concerns about an independent testing center relating to certification, credentialing, licensure, or academic admission services provided by the Pearson VUE Business Group please contact us at PearsonVUE Contracts@pearson.com or you may call us at 1 (952) 681-3918.

REMOTE PROCTORING TEST SERVICES

Description of Remote Proctoring Test Services

If a test sponsor offers their test outside of a Pearson VUE authorized testing center through remote proctoring and if you choose to take the test through Pearson VUE’s remote proctoring platform, you will be monitored over the Internet through your computer via your webcam and microphone. Remote proctoring means that you will log on to a test platform through the internet to take your test and you will be monitored during your entire testing session in real-time so that your face, voice, desk and workspace will be captured and a recording will be made of these images for the purposes of test security and the integrity of the testing process. It is your responsibility to monitor your remote proctored testing environment. You must make sure that only you will be recorded during your testing session and that no one else will be physically in the room where you are testing and that no one speaks to you during your testing session. If at any time during a remote proctored testing session a third party enters the work space or if any third party’s voice is detected on the audio recording your testing session may be immediately terminated and the test stopped. If this event occurs you will not receive a test refund or be credited for any portion of the test fee.

The video and audio recordings are standard test procedures for all test sponsors’ remote proctored tests and your video and audio recording will be used for purposes of identity verification, remote observation, incident resolution, such as fraud prevention, test security, and for the integrity of the test and testing process. For more information about how the test sponsor may collect and use your personal information we encourage you to review the test sponsor’s privacy policy.

Personal Information Collected for Remote Proctoring Test Services

All of the same personal information that we collect or receive as described above applies to you when you register to take a test sponsor’s remote proctored test. Prior to the start of your remote proctored test you may be required to hold up your ID documentation, (for example your driver license, passport or other approved ID that the sponsor designates), to be recorded on the video for the purpose of identity verification. The collection of such data is optional, but necessary if you choose to use the remote proctoring function. You understand that the audio- and video-tapes of your testing session will be supplied to the relevant test sponsor and any of their appointed agents to assist with their management of your test.

NCS PEARSON, INC. AS A TEST SPONSOR

PTE Professional

When you take the PTE Professional test, we use your personal information to:

  • Administer the PTE Professional test, the English for Professionals Exam.
  • Process your requests for products, services, or information and to communicate with you regarding such requests.
  • Verify your identity, process payments and collect debts you owe us.
  • Improve the Site and our other business systems and procedures.
  • Conduct research and produce aggregate statistical studies and analysis related to our products and services.
  • Ask you to participate in brief surveys regarding the products and services offered by PTE Professional.
  • Provide you with information about products, services or special offers from PTE Professional. Please see the section below entitled “Your Choices” to better understand your choices with regard to these communications from PTE Professional.

Your Choices

PTE Professional endeavors to provide you with choices regarding our use of your personal information. For example, although we may occasionally use your personal information to contact you regarding products or services of PTE Professional we think might be of interest you, you will be given instructions on how to opt out of receiving further communications of this nature by email. Should you elect to opt out of receiving further communications you may still receive program-related messages and similar transactional communications by email. In addition, as noted above, you will have the opportunity to choose not to receive marketing materials and communications from our affiliates or third parties.

IC3

When you take the IC3 test, we use your personal information to:

  • Administer the IC3 test, Internet and Core Computing Certification Exam.
  • Process your requests for products, services, or information and to communicate with you regarding such requests.
  • Verify your identity, process payments and collect debts you owe us.
  • Improve the Site and our other business systems and procedures.
  • Conduct research and produce aggregate statistical studies and analysis related to our products and services.
  • Ask you to participate in brief surveys regarding the products and services.
  • Provide you with information about products, services or special offers. Please see the section below entitled “Your Choices” to better understand your choices with regard to these communications from us.

Your Choices

We endeavor to provide you with choices regarding our use of your personal information. For example, although we may occasionally use your personal information to contact you regarding IC3 products or services we think might interest you, you will be given instructions on how to opt out of receiving further communications of this nature by email. Note, however, that in such a case, you will still receive program-related messages and similar transactional communications by email. In addition, as noted above, you will have the opportunity to choose not to receive marketing materials from our affiliates or third parties.

Testing of Minors under the Age of 13 for IC3

When children under the age of 13 wish to take an IC3 test requiring the collection of their personal information, we take steps to protect children’s privacy, including:

  • In accordance with applicable law, obtaining consent from parents for the collection of personal information of or from their children, or for sending information about our products and services directly to their children.
  • Limiting our collection of personal information from children to no more than is reasonably necessary to register, take and receive certification on an IC3 test.
  • Provide parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be updated accordingly.

INFORMATION POLICY RELATING TO TEST CENTER APPLICATIONS

Test Center Applications

Through the Test Center Applications available on this Site, a firm may apply to become a Pearson VUE® Authorized Test Center. Providing business entity data is voluntary, but necessary for completing a Test Center Application. You may stop completing the Test Center Application at any time before submitting it. We will use the data you provide on the Test Center Application to evaluate and qualify your application. Test Center Applications are subject to our acceptance and an applicant will not be considered a Pearson VUE Authorized Test Center until a definitive written agreement has been signed by both the applicant and Pearson VUE.

Transfer of Information

We may disclose and transfer to third parties the information supplied in a Test Center Application in the following situations: (a) in response to a subpoena, court order or legal process, to the extent permitted and required by law; (b) to protect user security or the security of other persons, consistent with applicable law; (c) in connection with a sale, joint venture or other transfer of some or all of the assets of NCS Pearson, Inc.; (d) to organizations who are working as contractors or agents to fulfill a service or supply a product on our behalf and who are committed or obliged to protect your privacy in a manner consistent with this Privacy Policy; and (e) as necessary or appropriate to evaluate and qualify the applicant. By submitting a Testing Center Application, you consent to this disclosure and transfer of information.

Information Access and Corrections

To access and correct any information supplied in a Test Center Application, please contact us at PVAmericasChannelSales@pearson.com or call (800) 247-8719 or +1 (952) 681-3000 (toll number).

Questions

If you have any questions or concerns about your Test Center Application or how we handle the data supplied in a Test Center Application, please contact us at PVAmericasChannelSales@pearson.com.

INFORMATION POLICY RELATING TO BUSINESS DEVELOPMENT SUBMISSION FORMS

Through the “Contact Business Development” form on this site, you may provide your contact information for the purpose of having a Person VUE Business Group representative contact you to discuss information about the products and services offered by the Pearson VUE Business Group. Providing your information is completely voluntary. The personal information that we collect or receive through the Contact Business Development form includes but not limited to: name, email address, phone number, company, title, primary place of business, and information about your testing program. We will use the information you submit to evaluate your needs and provide you information on services you may be interested in.

Information Access and Corrections

To access and correct any information supplied in the Contact Business Development form, please contact us at pvamericassales@pearson.com or call (888)-627-7357.

E-COMMERCE

Description of E-commerce Services

Pearson VUE’s e-commerce Sites provide you with the opportunity to purchase certification, credentialing, licensure, and academic admission test related products and services. Pearson VUE also provides e-commerce services on behalf of our test sponsors.

Personal Information Collected for Ecommerce Services

We clearly identify what information must be provided by you in order for us to deliver the various products, services, and information that you may request. Depending on your choices, we will require different types of information for these various products, services, and information. You may also choose to provide additional or optional information to enhance the services provided to you. The personal information that we may collect includes:

  • Contact and shipping information, as well as purchase history, and payment information.
  • Information regarding your use of the Site (i.e., pages visited, files downloaded). We will use this information to understand the habits of our Site users and to improve the products, services, and content we offer.
  • In the event you wish to ‘email a friend’ telling them about the products available on our e-commerce Sites, you will be given the opportunity to enter the friend’s email address, include your personal message, hit send and your message is on its way. We will not store the ‘email a friend’s’ address and we will not send any email messages to them beyond the ‘email a friend message’ you sent from our Site. No ‘email a friend’ email addresses will be sold or used for promotional purposes.

CREDENTIALING SERVICES

Description of Credentialing Services

We provide credentialing services as a service provider on behalf of credentialing sponsors (that act as an autonomous data controller) and we provide testing services on behalf of ourselves. The credentialing sponsor is the company or organization that offers the credential you are seeking. We collect or receive personal information from credentialing candidates on behalf of the test sponsor. We use this personal information in order to perform the credentialing services on behalf of the test sponsor. The information we may collect or receive includes, but is not limited to, your credentialing information, collection of payment for credentialing services you’ve requested, your test results resulting from your testing of the sponsor’s test, and communicating with you about credentialing services. Providing your personal information is voluntary, but necessary if you wish to participate in the credentialing services. We will handle and treat all personal information collected and received by us in connection with the credentialing services in the manner as described in this Privacy Policy. For more information about how the credentialing sponsor may collect and use your personal information we encourage you to review the credentialing sponsor’s privacy policy.

Personal Information Collected for Credentialing Services

The personal information that we collect or receive in registering you for credentialing services include: name, address, email address, phone number, fax number, credit/debit card information, company and title. We may also collect or receive the following additional information at registration or in the testing process, as necessary or appropriate, including but not limited to: language, date of birth, social security number, sponsor identification number, employment information, testing history, education information, and source of financing for your tests. For candidate verification and identification purposes, we may collect all or part of a government-issued identification number and mother’s maiden name.

THIRD PARTY WEBSITES AND SOCIAL MEDIA

We may also collect information via third party websites such as Google, or via social media such as Twitter and Facebook. This information may include your name, address, username, email address, website visited, content posted, IP address, nationality, language, and other publicly available demographics. This information is used to improve the products and services that we offer, to identify and resolve customer service issues, and to provide the information and services you request.

INFORMATION RECEIVED FROM INTERNET SERVICE PROVIDERS THROUGH THIS SITE

This Site receives information that is automatically generated by a user’s Internet service provider (ISP), browser or mobile device. This information may include the IP address, the associated URLs, domain names, the browser type, the approximate location of the ISP’s servers, the pages of our Site that the user views, and any search terms entered on this Site. This information may be collected for system administration purposes, to gather broad demographic information and to monitor the level of activity on the Site. We reserve the right to link this information to your personal information in order to protect the integrity of our system and for security purposes.

TRANSFER OF INFORMATION

Data collected and received by us will be transmitted to the United States and depending on the services you participate in, your data may also be transferred to other countries. Our computer operations are currently based in the United States. The Internet is a global environment. By using this Site and sending information to us electronically, you consent to trans-border and international transmission of any data that you may choose to supply us to any country in the world, including countries without an adequate level of data protection. Information transmissions to this Site and emails sent to us may not be secure. Given the inherent operation and nature of the Internet, all Internet transmissions are done at the user’s own risk.

Transfer of Information to Test Sponsors (If applicable)

By registering for a test through us, purchasing services or products from one of our e-commerce Sites, or submitting information to one of our credentialing Sites, or in some cases submitting your personal information through a third party acting upon your direction and on your behalf, you give your consent for your personal information to be transmitted by us to the test sponsor from whom you seek certification, credentialing, licensure, or academic admission or on whose behalf the e-commerce Sites are administered by the Pearson VUE Business Group. The test sponsor requires your personal information so that (a) tests can be correctly administered; (b) certification, credentialing, licensure, or academic admission can be processed, granted and administered; and (c) candidates can receive further information about certification, credentialing, licensure, or academic admission testing. For more information about how the test sponsor may collect and use your personal information we encourage you to review the test sponsor’s privacy policy.

Other Transfer of Information

We may disclose personal information in the following situations: (a) in response to a subpoena, court order or legal process, to the extent permitted and required by law; (b) to protect your security, or the security of other persons, consistent with applicable law; (c) to address actual or suspected fraud or other illegal activities; (d) in connection with a sale, joint venture or other transfer of some or all of the assets of NCS Pearson, Inc.; and (e) to our subcontractors or agents (such as, those third parties hosting one or more of our website’s; processing credit card transactions and payments; fulfilling and processing orders; assisting us with marketing and promotions; and collecting web analytics data, etc.), including independent testing centers, if any, solely for the purpose of enabling them to perform services on our behalf.

The Pearson VUE Business Group will have agreements in place with these third party subcontractors prior to the transfer of any personal information requiring that such subcontractor provide at least the same level of privacy protection as that set forth in EU-U.S. Privacy Shield Principles and the U.S-Swiss Principles and instructions that the subcontractor may only use the data for the purposes identified by the Pearson VUE Business Group in such agreement. In cases of onward transfer to third parties of personal information of European Union and its Member States individuals received pursuant to the EU-US Privacy Shield, we are not responsible for the processing of personal information by any third party, other than those third parties acting as our subcontractors to process data on our behalf.

For purposes of validating test and user integrity and security, we may supply audio- and video-tapes of test candidates in a testing center at a particular time to any test sponsor whose test was being administered at that time in such test center. Where you have chosen to take your test through our remote proctoring platform, the audio- and video-tapes of your testing session will be supplied to the relevant test sponsor and any of their appointed agents to assist with their management of your test.

By registering for a test through us, or in cases when we receive your personal data from a third party acting upon your direction and on your behalf, you give your consent for your personal information to be transmitted in the situations outlined above.

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We do not provide your personal information to any parties who at not connected with the services we provide or relate to such products or services unless you agree. Except as disclosed in this Privacy Policy, we will not provide your data to third parties.

INFORMATION FROM CHILDREN

We recognize the importance of protecting privacy where children are involved. We are committed to protecting children's privacy and we comply fully with the Children's Online Privacy Protection Act (COPPA) and similar laws and regulations. Except in the case of the IC3 Exam, we do not knowingly collect personal information from children under the age of 13. If a child under the age of 13 has provided us with personal information, we ask that a parent or guardian contact us at PearsonVUEContracts@pearson.com or you may call us at 1 (952) 681-3918. If you are under 18, please be sure to read this Privacy Policy with your parent(s) or legal guardian(s) and ask questions about things you do not understand.

AGGREGATION OF NON-PERSON-SPECIFIC DATA

We may statistically aggregate in non-person-specific form test responses and other information collected in the certification, credentialing, licensure, and academic admission test registration and delivery process and transfer this information to test sponsors and to independent testing centers. Such aggregated non-person-specific information may be used for quality control, operations management, security and marketing purposes and to enhance develop or improve certification, credentialing, licensure, and academic admission testing processes, testing services, tests and related products and services. By registering for a test through us, you give to us your consent to this non-person-specific data aggregation and the use and transmission of this aggregated statistical data as outlined herein.

EMAIL NEWSLETTERS

We may use your email address to send you email newsletters about certification, credentialing, licensure, or academic admission testing. You may opt out of receiving the newsletter at any time by notifying us by email at PVMarketing@pearson.com or following the opt-out instructions provided in the email newsletter.

INFORMATION ACCESS AND CORRECTIONS

To access and correct the personal information that we have collected under this Privacy Policy, please contact our Call Center or send us an email at PearsonVUEContracts@pearson.com. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making alterations.

PROTECTION OF CREDIT CARD INFORMATION

Individuals who make online purchases will be asked to provide credit/debit card information, which may include payment instrument number (e.g., credit card), name and billing address, the security code associated with the credit/debit card information, organizational tax ID, and other financial data ("Payment Data"). We use Payment Data to complete transactions, as well as to detect and prevent fraud. We will retain your Payment Data for as long as reasonably necessary to complete the transaction, to comply with our legal and reporting requirements, and to detect and prevent credit/debit card fraud. We provide a secured transmission method for the electronic transmission of credit/debit card information.

RESOLUTION OF CONCERNS

Questions or concerns regarding the use or disclosure of personal information should first be directed to PearsonVUEContracts@pearson.com or you may call us at 1 (952) 681-3918. We will investigate and attempt to resolve the complaint regarding the use and disclosure of personal information by reference to the Principles identified in our Privacy Policy.

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you believe you have not received a timely or satisfactory response from Pearson VUE you should contact (free of charge) your state or national data protection authority. A list of National Data Protection Authorities can be found by clicking on National Data Protection Authorities. Pearson VUE has committed to cooperate with the Data Protection Authorities and will comply with the information and advice provided to it by the panel of DPAs in relation to such unresolved complaints.

As further explained on the Privacy Shield website at https://www.privacyshield.gov, as a last resort and in limited situations, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

COOKIES AND WEB BEACONS

Cookies. Cookies are small text files that a web server places on your computer or mobile device. Cookies contain information that can later be read by the web server that originally placed the cookie on your computer or mobile device.

Below is a list of the main types of cookies we use and what we use them for:

  1. Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of this Site. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.
  2. Performance Cookies: These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. Some of the performance cookies are analytics cookies using third party web analytics software, which allow us to understand more about how our Site is used. For example, like many companies we use Google Analytics, which may use performance cookies. We use Google Analytics to obtain web trend information about user interaction with this Site. We use this information for system administration purposes and to identify problems and improve service. While Google Analytics collects and reports information on an anonymous basis, Google Analytics uses cookies and collects IP addresses to gather web trend information. For more information about Google Analytics, and for links to Google’s Privacy Policy and an opt-out tool for Google Analytics, go to www.google.com/intl/en/analytics/privacyoverview.html. Performance cookies are not used to collect information that identifies a visitor. All information these performance cookies collect is aggregated and therefore anonymous. The aggregated data is only used by us to improve how our Site works. We might also use performance cookies to highlight our products or services which we think will be of interest to you based on your use of our Site. By using this Site you agree we may place these types of cookies on your device.
  3. Functionality Cookies: These cookies allow the Site to remember choices you make (such as your user name, language or the region you are located in) and provide enhanced, more personal features. For instance, these cookies can be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies is not used to track your browsing activity on other websites. These cookies are known as “functionality cookies” and help to improve a user’s experience of a website by providing a more personalized service. By using this Site you agree we may place these types of cookies on your device.
  4. Targeting or advertising cookies: These cookies are used to deliver advertising materials relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization. Most of our Sites do not use targeting cookies. By using this Site you agree we may place these types of cookies on your device.

3rd Party Cookies and Social Networks. If you click on a hyperlink from this Site to any third party websites (for example, if you 'share' content from our Site with friends or colleagues through social networks) or use third party services together with this Site, you may be acquire cookies from these third party websites. Third party websites will have their own privacy and cookie policies which we do not and cannot control. Please check the third-party websites for more information about their cookies and how to manage them. You should always review these third-party websites privacy policies.

How to manage cookies

If you block cookies or cookies are not enabled on your computer, it will mean that your browsing or shopping experience on our websites will be limited. Some active content, movies and online shopping baskets, for example, may not work correctly.

To turn cookies on or off for all of our websites via your web browser, you can follow the instructions provided by the UK Information Commission Office at ico.org.uk/for-the-public/online/cookies.

Web Beacons. Web Beacons are small strings of code that provide a method for delivering a graphic image on a web page for the purpose of transferring data. For example, when you visit a page on this Site, the code for the page being visited may be transferred to us. The information transmitted to us is only used internally by us and is not shared with any third parties, except as provided in this Privacy Policy. We use this information for the following purposes:

  • To allow us to better understand the traffic patterns within our websites and, subsequently, to adjust our content to better respond to our visitors interests; and
  • To use the information we obtain to suggest materials and resources that may be of interest to you based on your use of our Site.

By using this Site, you agree to the our use of the cookies as described above and to our use of web beacons for the collection of information in order to provide the products or services you have requested and for improvements, as we deem appropriate in our sole discretion, related to our products and services.

Do Not Track Signals. This Site does not respond to web browser “do not track” signals or comparable signals or mechanisms.

UPDATES TO THIS PRIVACY POLICY

We reserve the right to update the terms of this Privacy Policy from time to time. We encourage you to visit and review this Privacy Policy periodically to ensure you agree with any changes or updates. We will post our revised privacy notice on our website and update the ‘Revision Date’ to reflect the date of the changes.

By continuing to use our website after we post any such changes or updates you accept the privacy notice as modified.

HOW TO CONTACT US

Revision Date of September 27, 2016