Last Updated: August 22, 2019
TABLE OF CONTENTS:
2. INFORMATION WE COLLECT
3. HOW WE USE THE INFORMATION WE COLLECT
4. SHARING & DISCLOSURE
5. OTHER IMPORTANT INFORMATION
6. YOUR RIGHTS
7. OPERATING GLOBALLY & INTERNATIONAL TRANSFERS
10. CONTACT US
Thank you for using the OperatorPro Services! The OperatorPro Services are provided to you by Industrial Training International, Inc., a Washington corporation (“ITI”). Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with all Services.
2. INFORMATION WE COLLECT
There are three general categories of information we collect.
2.1 Information You Give to Us.
2.1.1 Information that is necessary for the use of the Services. We ask for and collect the following personal information about you when you use the Services. This information is necessary for the adequate performance of the Services and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested Services.
· Account Information. When you sign up for an Operator account, we require certain information such as your first name, last name and email address.
· Profile and Listing Information. To use certain features of the Services, we may ask you to provide additional information, which may include your address, city where you work or otherwise.
· Payment Information. To use certain features of the Services, we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
· Communications with Us and other Operators. When you communicate with us or use the Services to communicate with other Operators, we collect information about your communication and any information you choose to provide.
2.1.2 Information that is necessary for the payment for Services.We need to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to pay for the Services, which could restrict your access to certain features or functions of the Services:
· Payment Information. When you wish to subscribe for Services, we require certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.
· Identity Verification and Other Information. If you are an Operator subscribing for Services, we may require identity verification information or other authentication information, your date of birth, your address or email address and other information in order to verify your identity, provide the Services to you, and to comply with applicable law.
2.1.2 Information you choose to give us.You may choose to provide us with additional personal information in order to obtain a better user experience when using the Services. This additional information will be processed based on our legitimate interest or when applicable, your consent.
· Additional Profile Information. You may choose to provide additional information as part of your profile or in connection with your use of the Services (such as company affiliation, job title, or a profile picture). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
· Address Book Contact Information. You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the Services, like inviting them to use the Services.
· Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us (such as through Feedback), or use other features of the Services.
2.1.3 Information We Automatically Collect from Your Use of the Services.When you use the Services, we automatically collect personal information about the Services you use and how you use them. This information is necessary for the adequate performance of the Services, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Services.
· Geo-location Information. When you use certain features of the Services, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. We may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
· Usage Information. We collect information about your interactions with the Services such as the pages or content you view, your Shift information or records input, and other actions on the Services.
· Log Data and Device Information. We automatically collect log data and device information when you access and use the Services, even if you have not created an Account or logged in. That information includes, among other things: details about how you’ve used the Services (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Services.
Your browser can help you manage cookies. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings on each browser and device that you use. Each browser is different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to many features that make our Services more efficient and some of our Services will not function properly. There are also general resources for opting out of interest based advertising available on the websites of the Network Advertising Initiative and the Digital Advertising Alliance.
Similarly, you can adjust your advertising preferences on your mobile device at the device level. For example, to adjust your advertising preferences in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads.
· Do Not Track Signals. While you may disable the usage of cookies through your browser settings, the Services currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.
· Payment Transaction Information. We may collect information related to your payment transactions through the Services, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and us and to allow the provision of the Services in certain instances, such as when an Operator subscribes for the use of the Services.
2.1.4 Information We Collect from Third Parties.We may collect information (including personal information) that others provide about you when they use the Services, or obtain information from other sources and combine that with information we collect through the Services. We do not control, supervise or respond for how the third parties providing your information process your personal information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
· Third Party Services. If you link, connect, or login to your Account with a third party service (e.g. Facebook, LinkedIn), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
· Referrals. If you are invited to use any of the Services, the person who invited you may submit personal information about you such as your email address or other contact information.
· Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. We may receive information about you and your activities on and off the Services through partnerships, or about your experiences and interactions from our partner ad networks.
2.2 Children’s Data. You must be 18 years or older to use the Services. Our Services are not directed to, or intended for use by, children under 18 and we do not knowingly collect any personal information directly from children under 18. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.
3. HOW WE USE INFORMATION WE COLLECT
We may use, store, and process personal information to: (1) provide, understand, improve, and develop the Services, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with all ITI Policies); and (3) provide, personalize, measure, and improve our advertising and marketing.
3.1 Provide, Improve, and Develop the Services. We may use the personal information to provide, improve, and develop the Services such as to:
· enable you to access and use the Services,
· enable you to communicate with other Operators,
· operate, protect, improve, and optimize the Services and experience, such as by performing analytics and conducting research,
· provide customer service,
· send you service or support messages, updates, security alerts, and account notifications,
· if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection,
· to operate, protect, improve, and optimize the Services and experience, and personalize and customize your experience, and conduct profiling based on your interactions with the Services, your shift information, your profile information and preferences, and other content you submit to the Services.
We process this personal information for these purposes given our legitimate interest in improving the Services and our Operators’ experience with it, and where it is necessary for the adequate performance of the contract with you.
3.2 Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and maintain a trusted and safer environment such as to:
· detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
· conduct security investigations and risk assessments,
· verify or authenticate information or identifications provided by you,
· comply with our legal obligations,
· Resolve any disputes with any of our Operators and enforce our agreements with third parties,
· enforce our Terms of Service and other policies, and
· in connection with the activities above, we may conduct profiling based on your interactions with the Services, your profile information and other content you submit to the Services, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Services if such processes detect activity that we think poses a safety or other risk to the Services, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.
We process this personal information for these purposes given our legitimate interest in protecting the Services, to measure the adequate performance of our contract with you, and to comply with applicable laws.
3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:
· send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about ITI or partner campaigns and services) and social media advertising through social media platforms such as Facebook or LinkedIn),
· personalize, measure, and improve our advertising,
· administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by ITI or its third party partners,
· conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Services, information obtained from third parties, and your search and Shift history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,
· enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have an Account, and
· invite you to events and relevant opportunities.
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.
Please note that even if you opt-out of marketing communications, we may still need to contact you with important transactional information about your Account. For example, even if you opt-out of emails, we may still send you activity confirmations or fraud alerts.
4. SHARING & DISCLOSURE
4.1 Advertising and Social Media; Sharing With Your Consent. Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Account or when you participate in promotional activities conducted by partners or third parties.
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or LinkedIn, to generate leads, drive traffic to our application or otherwise promote our products and services or the Services. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.
The social media platforms with which we may share your personal information are not controlled or supervised by us. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.
Please note that you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to the contact address set forth in Section 10, below.
4.2 Sharing between Operators. To help facilitate the Services or other interactions between Operators, we may need to share certain information, including personal information, with other Operators, as it is necessary for the adequate performance of the contract between you and us, as follows:
When you as an Operator choose to connect with other Operators, certain information about you is shared with the other Operator, including your profile, full name, your Shift information and records and other information you agree to share.
Other functions to connect Operators may be available through the Services. In the event you use these Services and connect with other Operators, we may need to share certain additional information you’ve provided to us, including equipment competence evaluations, Shift record certifications and other Shift data.
4.3 Profiles and other Public Information. The Services lets you publish information if you so choose, including personal information, that may be visible to the general public. For example, parts of your profile page, such as your first name and your employer may be publicly visible to others.
If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Services, that content may be publicly visible.
Information you share publicly on the Services may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
4.4 Compliance with Law, Legal Requests, Preventing Harm and Protection of our Rights. We may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against us or our affiliates, (iii) to respond to valid requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service or other agreements with Operators, or (v) to protect the rights, property or personal safety of us, our employees and agents, Operators, or the public.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Services secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.
Where appropriate, we may notify Operators about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon our property, other Operators or the Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Operator about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
4.5 Service Providers. We use a variety of third-party service providers to help us provide services related to the Services. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe and North and South America.
For example, service providers may help us: (i) verify your identity or authenticate your identification information, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims. These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions. We will need to share your information, including personal information, in order to ensure the adequate performance of the Services.
4.6 Corporate Affiliates. To enable or support us in providing the Services, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.
Even if your country of residence is not the United States, your information may be shared with other ITI corporate affiliates which provides the technical infrastructure for the Services, product development and maintenance, customer support, trust and safety and other business operation services to other ITI entities. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the Services globally.
Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve the Services and our affiliates’ services.
4.7 Business Transfers. If ITI undertakes or is involved in any merger, acquisition, reorganization, sale of assets, sale of shares, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including, without limitation, your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence).
4.8 Aggregated Data. We may also share aggregated information (information about our Operators that we combine together so that it no longer identifies or references an individual Operator) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.
5. OTHER IMPORTANT INFORMATION
5.1 Analyzing your Communications. We may review, scan, or analyze your communications on the Services for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
These activities are carried out based on our legitimate interest in ensuring compliance with applicable laws and our Terms of Service, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
5.2 Linking Third Party Accounts. You may link your Account with your account at a third party social networking service, such as LinkedIn or Facebook. Your contacts on these third party services are referred to as “Friends.” When you create this link:
o some of the information you provide to us from the linking of your accounts may be published on your Account profile;
o your activities on the Services may be displayed to your Friends on the Services and/or that third party site;
o a link to your public profile on that third party social networking service may be included in your OperatorPro public profile;
o other Operators or users of third party accounts may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
o other Operators may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service;
o the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
o the publication and display of information that you provide to us through this linkage is subject to your settings and authorizations on the Services and the third party site.
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
We may collect analytics data, or use third-party analytics tools, such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our Operators. We may share a unique identifier, like an Operator ID or hashed email address, with such third-party to facilitate the Services.
Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at https://policies.google.com/privacy/partners. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On athttps://tools.google.com/dlpage/gaoptout.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service.
You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available athttps://google.com/ads/preferences or by visiting NAI’s online resources at https://www.networkadvertising.org/choices.
6. YOUR RIGHTS
You may exercise any of the rights described in this section by sending an email to the contact address provided in Section 10. Please note that we may ask you to verify your identity and request before taking further action on your request.
6.1 Managing Your Information. You may access and update some of your information through your Account settings. If you have chosen to connect your Account to a third-party application, like Facebook or LinkedIn, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
6.2 Rectification of Inaccurate or Incomplete Information. You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Account).
6.3 Data Access and Portability. In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.4 Data Retention and Erasure. We generally retain your personal information for as long as is necessary for the performance of the Services and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information:
· We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Account for fraud or safety reasons, we may retain certain information from that Account to prevent that Operator from opening a new Account in the future.
· We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
· Information you have shared with others (e.g., Reviews, Shift records, equipment competence evaluations) may continue to be publicly visible on the Services, even after your Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain the Services to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.5 Withdrawing Consent and Restriction of Processing. If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where: (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether our legitimate grounds for the retention/processing of your personal information override your own.
6.6 Objection to Processing. In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing by us, we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to the contact address in Section 10, below.
6.7 Lodging Complaints. You have the right to lodge complaints about our data processing activities by filing a complaint with our office, which can be reached by the “Contact Us” section below or with a supervisory authority.
7. OPERATING GLOBALLY & INTERNATIONAL TRANSFERS
7.1 California & Vermont Residents. We will not share information that we collect about you with our affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.
7.2 California Privacy Rights. California law permits Operators who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact Us” section for where to send such requests. We do not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the Contact Us section below.
10. CONTACT US
Log shifts and activities by make, model and configuration. View and share robust dashboards and reports on all hours, shifts, activities, evaluations on yourself and others, weather conditions, GPS location tracking and more. Track and record your activities including shifts, lifts, inspections, assembly/disassembly and evaluations.