The following Privacy Policy outlines the practices of Vigilance Risk Solutions, Inc. (“VRS”) with respect to the information gathered about individuals who purchase licenses to VRS online training courses hosted through the Absorb LMS platform.

Types Of Personal Information That We Collect

When creating an account or purchasing a license to the access of use an online training program (each, a “Training”), we will collect basic information which may include (but is not limited to) your name, physical address, email address, and phone number[DD1]  (collectively, “Personal Information”). VRS does not automatically collect any information during the registration process that is not directly provided by you. VRS collects and retains the minimum amount of information reasonably needed to identify and maintain your account.

Uses And Disclosure Of Personal Information

VRS does not sell Personal Information to third party organizations (each, a “Third Party”), and does not provide Personal Information to Third Parties for purposes other than servicing user accounts and processing payments. Typical uses of your Personal Information include:

– Processing registrations and payments for licenses to Trainings- Providing troubleshooting and support services to users- Sending administrative and other necessary information, such as access keys and changes to terms and policies, to users- Conducting internal analysis and audits, including analysis for the purpose of assessing product usage and effectiveness to improve content or develop new content

Additionally, VRS may disclose Personal Information when we reasonably believe such disclosure is necessary, including but not limited to (i) disclosure for the purpose of enforcing terms of use or investigating violation of such terms, (ii) acting in compliance with a lawful order from a court or governmental entity, or (iii) to protect the rights and safety of VRS, VRS property, users of the VRS Training, or the public. VRS may also disclose or transfer personal information in the event of a corporate acquisition, merger, or other restructuring, but only (i) if the receiving party agrees to treat your Personal Information in a manner that is consistent with this Privacy Policy, or (ii) if you are given prior notice of the change and are given the choice to cancel your account prior to such transaction.

Storage And Security Of Personal Information

Personal Information that we collect is not stored outside of the Absorb LMS hosting platform unless you specifically provide Personal Information to us in an external format for bulk registration purposes. Reasonable administrative, physical, and managerial steps will be taken to ensure the security and integrity of your Personal Information, including limiting access to the VRS Administrative Portal of the Absorb LMS hosting platform. No preventative measures can result in complete security, however, so we cannot guarantee the security and integrity of your information. VRS does not have access to your account password, but has the ability to generate a new temporary password if needed. Because VRS has limited access to user accounts and cannot necessarily prevent unauthorized use of your account by individuals who have access to your login information, you should take reasonable steps to protect this information from theft or misuse.

Online Tracking; Privacy Policies Of Key Third Party Service Providers

VRS may track your Training activity using information generated by the Absorb LMS hosting platform to determine course participation/completion and assess course performance; VRS will not otherwise directly track or store information about your web browsing or activities outside of the Training using cookies, web beacons, or any other technological means. Third Party service providers, however, including the Absorb LMS content hosting platform where the Training is accessed and viewed, and the Authorize.net payment gateway where payments are processed, may have different policies regarding the collection, storage, and use of your Personal information, as well as online tracking and responses to “Do Not Track” signals. VRS utilizes Third Party service providers to assist in providing content to you, but VRS does not control the information gathered by these Third Parties, including information collected by the LMS platform on which the Trainings are hosted; we suggest that you carefully review their privacy policies. The policies for Absorb LMS and Authorize.net can be found at the following web addresses:

https://www.authorize.net/company/privacy/https://www.absorblms.com/about/privacy-policy/

Retention And Modification Of Personal Information

Personal Information collected by VRS can be viewed in your user account on the Absorb LMS Platform, and is retained by VRS until your user account is deleted. Corrections and changes to your Personal Information can generally be made by you through your user account in the LMS portal. If you have any questions or concerns about our privacy policies, need to make changes to your Personal Information and are unable to do so through your account on the Absorb LMS platform, or would like to review the Personal Information about you that has been collected by VRS, please write or email us at one of the following addresses:

If By Mail:Attn: Data Privacy GroupVigilance Risk Solutions, Inc.2159 India St.San Diego, CA 92101

If By Email:contact@vigilancerisk.com

Updates To VRS Privacy Policies

VRS may update this Privacy Policy in response to changes in operational practices, the law, or other requirements, and will provide notice of any such changes (including when they will take effect) in accordance with the law. Your continued use of the Training after any such updates will constitute acceptance of those changes. If you do not accept the terms of an update that is made to this Privacy Policy, you may contact us by mail or email at the address listed above to request that your user account be deleted. Note that deletion of your user account will result in the loss of Certificates of Completion and other user information unless such items are saved by you prior to account termination. To see when this Privacy Policy was last updated, please see below.

(This Privacy Policy was last updated on November 27, 2017.)

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