OpenSesame Values Your Privacy

This Privacy Policy (this “Policy”) describes how OpenSesame Inc. (“OpenSesame”), treats information collected from you at the OpenSesame web site (http://www.opensesame.com) (the “Site”) and how it uses and discloses such information.

By accessing the Site, you consent to the collection, use and disclosure of your information in accordance with the terms of this Policy.If you do not wish your information to be collected, used or disclosed in the manners described in this Policy, please do not access the Site or make use of OpenSesame’s training services and related goods.

 

OpenSesame may collect two types of information:

 
Aggregate Information. For purposes of this Policy, information that is anonymous, aggregate information (such as pages visited on the Site, browser type, referring URL, IP address) will be referred to as “Aggregate Information.” Aggregate Information is not connected to you or to any other personally identifiable information relating to you.
Personal Information. For purposes of this Policy, personally identifiable information that is connected to you or other personally identifiable information relating to you, including, but not limited to your name, billing address, payment information, home address, electrical license information, telephone number, email address, birth date, or gender, will be referred to as “Personal Information.”
 

Children under 13

 
OpenSesame complies with requirements of the Children’s Online Privacy Protection Act
(COPPA) and the FTC’s Rule interpreting COPPA (16 CFR § 512). The Site is not directed to
children of any age and OpenSesame does not knowingly collect any Personal Information from
children under 13 years in any manner.
 

Use of Information

 
Aggregate Information. OpenSesame uses Aggregate Information only to generate statistical
reports, such as reports about the use of the Site. Such reports are used to make the Site
better meet your needs or to allow OpenSesame to better conduct its business.
 
Personal Information. OpenSesame uses Personal Information to fulfill your requests for certain
products and services; to customize the content you see; and to contact you about specials and
new products. OpenSesame reserves the right to use third party providers to assist in providing
services such as shipping, credit card processing, and communication regarding OpenSesame's
services. When OpenSesame uses third parties such as these, OpenSesame requires that the
third parties comply with this Policy and any other appropriate confidentiality and security
measures. OpenSesame may also share Personal Information with third parties in limited
circumstances, including when complying with legal process, preventing fraud or imminent
harm, and ensuring the security of OpenSesame’s network and services.
 

Disclosures of Information

 
Personal Information. OpenSesame does not sell, rent or share personally identifiable
information to or with any third party not affiliated with or owned by OpenSesame, except that
OpenSesame may disclose such information to service providers who may assist OpenSesame
in providing services to you or in such areas reporting the completion of certain types of training.
OpenSesame will disclose your personal information to third parties when you give us
permission to do so. If you create a public profile on OpenSesame, any information you include
in that profile will be disclosed publicly.
 
Aggregate Information. Aggregate information is used solely for internal purposes to help
OpenSesame improve its users’ experience at the Site and to better provide its services to you.
Cookies. OpenSesame may use “cookies” to recognize and count new visitors and to acquire
Aggregate Information that lets OpenSesame analyze traffic patterns and tune the performance
and functionality of the Site. A cookie is a file that is placed on your hard drive when you visit a
website. It contains specific information that allows the Site to “recognize” your computer the
next time you visit. The most important use for cookies is to eliminate the need for you to
re-enter your information every time you visit the Site. Most browsers accept cookies by default,
but you can turn off cookies using your browser settings. To learn how, see: for Microsoft
Internet Explorer users, www.microsoft.com/info/cookies.htm; for Firefox users,
certain Site features may no longer work or may work differently. Please note that when you
accept a cookie from the Site, OpenSesame does not gain access to your hard drive or
personal information other than the information you have provided to us. OpenSesame does
not provide cookie information to any third party.
 
Disclosure as Required by Law. OpenSesame will disclose user Personal Information when
required by law or if OpenSesame has a good faith belief that such action is necessary to
comply with a current judicial proceeding, a court order or legal process served on OpenSesame.
 
Business Transition. In the event OpenSesame goes through a business transition, such as a
merger, acquisition by another company or a sale of a portion of OpenSesame’s assets, our
customers’ Personal Information may be part of the assets transferred. Disclosure of users’
Personal Information in such a situation, or in contemplation of such a situation, shall be
deemed consistent with this Policy. However, such a transfer may result in a change in this
Policy, and you are advised and strongly encouraged to review this Policy frequently.
 
Links. The Site contains or may contain links to other web sites. OpenSesame is not responsible for the privacy practices or content of these other web sites. This Policy applies solely to information collected by the Site. OpenSesame encourages you to be aware when you leave the Site and to read the privacy statements of each and every web site that collects Personally Information. 
 
Security. OpenSesame takes commercially reasonable precautions to protect your information. However, given the nature of the Internet and the fact that network security measures are not infallible, OpenSesame cannot guarantee the security of Personal Information submitted through the Site. OpenSesame also makes an offline effort to protect your Personal Information. OpenSesame makes commercially reasonable efforts to restrict access to Personal Information to employees who need the information to perform a specific job. OpenSesame maintains commercially reasonable physical, electronic and managerial procedures to safeguard the
Personal Information OpenSesame collects.
 
Contacting, Updating and Opting Out. You may use the contact information provided below to request a change in your Personal Information (such as address correction) or to have your Personal Information removed from OpenSesame’s database. OpenSesame will correct, update, or remove your Personal Information according to your request. You may also use the contact information below if you have any questions, comments or complaints about this Policy or your dealings with the Site.
 
OpenSesame info@OpenSesame.com 
520 NW Fifth Street, Suite 200, Portland, OR 97209
United States of America (503) 808-1268
 

EUUS Privacy Shield Privacy Statement

 
OpenSesame has adopted this Privacy Shield Policy ("Policy") to establish and maintain an
adequate level of Personal Data privacy protection. This Policy applies to the processing of
Personal Data that OpenSesame obtains from Customers located in the European Union and
Switzerland. OpenSesame complies with the USEU Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Individual Customers in the European Union member countries. OpenSesame has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov .
 
The Federal Trade Commission (FTC) has jurisdiction over OpenSesame's compliance with the
Privacy Shield. OpenSesame complies with the US Swiss Safe Harbor Framework as set forth by the US  Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. OpenSesame has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the Safe Harbor program, and to view our certification page, please visit http://2016.export.gov/safeharbor/swiss/index.asp. All OpenSesame employees who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.
 
Capitalized terms are defined in Section 14 of this Policy.

 

I. SCOPE

 
This Policy applies to the processing of Individual Customer Personal Data that OpenSesame
receives in the United States concerning Individual Customers who reside in the European
Union and Switzerland. OpenSesame provides products and services to businesses and
consumers. This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
 

II. RESPONSIBILITIES AND MANAGEMENT

 
OpenSesame has designated the Legal Department to oversee its information security program,
including its compliance with the EU Privacy Shield program and Swiss Safe Harbor. The Legal
Department shall review and approve any material changes to this program as necessary. Any
questions, concerns, or comments regarding this Policy also may be directed to
CustomerSupport@OpenSesame.com. OpenSesame will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. OpenSesame personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that OpenSesame has undertaken to protect Personal Data.
 

III. RENEWAL / VERIFICATION

 
OpenSesame will renew its EU Privacy Shield and US Swiss Safe Harbor certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism. Prior to the recertification, OpenSesame will conduct an in house verification to ensure that its attestations and assertions with regard to its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, OpenSesame will undertake the following:
 
1. Review this Privacy Shield policy and its publicly posted website privacy policy to ensure
that these policies accurately describe the practices regarding the collection of Individual Customer Personal Data
 
2. Ensure that the publicly posted privacy policy informs Individual Customers of
OpenSesame's participation in the EU Privacy Shield and US Swiss Safe Harbor
programs and where to obtain a copy of additional information (e.g., a copy of this
Policy)
 
3. Ensure that this Policy continues to comply with the Privacy Shield and the Swiss Safe
Harbor principles
 
4. Confirm that Individual Customers are made aware of the process for addressing
complaints and any independent dispute resolution process (OpenSesame may do so
through its publicly posted website, Individual Customer contract, or both)
 
5. Review its processes and procedures for training Employees about OpenSesame's
participation in the Privacy Shield and Swiss Safe Harbor programs and the appropriate
handling of Individual's Personal Data OpenSesame will prepare an internal verification statement on an annual basis.
IV. COLLECTION AND USE OF PERSONAL DATA
 
OpenSesame provides various solutions to its Individual Customers who purchase its products.
OpenSesame collects Personal Data from Individual Customers when they purchase its
products, register with our website, login to their account, complete surveys, request information or otherwise communicate with us. For example, OpenSesame individual customers may choose to seek live support.
 
The Personal Data that we collect may vary based on the Individual Customer's interaction with
our website and request for our services. As a general matter, OpenSesame may collect the
following types of Personal Data from its Individual Customers: contact information, including, a
contact person's name, work email address, work mailing address, work telephone number, title,
and company name, as well as payment information (which might include credit card and/or
bank account information). Individual customers have the option to log into their accounts online
and to request service online, including through a live support option; we will collect information
that they choose to provide to us through these portals.
 
When Individual Customers use our services online, we will collect their IP address and browser
type. We may associate IP address and browser type with a specific customer. We also may
collect Personal Data from persons who contact us through our website to request additional
information; in such a situation, we would collect contact information (as discussed above) and
any other information that the person chooses to submit through our website.
 
The information that we collect from Individual Customers is used for selling the products and
services they buy from us, managing transactions, reporting, invoicing, renewals, other
operations related to providing services and products to the Individual Customer.
 
For certain products, OpenSesame serves as a service provider. In our capacity as a service
provider, we will receive, store, and/or process Personal Data. In such cases, we are acting as a
data processor and will process the personal information on behalf of and under the direction of
our partners and/or agents. The information that we collect from our Individual Customers in this
capacity is used for managing transactions, reporting, invoicing, renewals, other operations
related to providing services to the Individual Customer, and as otherwise requested by our
partner and/or agent.
 
OpenSesame uses Personal Data that it collects directly from its Individual Customers and for
its partners indirectly in its role as a service provider for the following business purposes, without limitation:
 
1. maintaining and supporting its products, delivering and providing the requested
products/services, and complying with its contractual obligations related thereto
(including managing transactions, reporting, invoices, renewals, and other operations
related to providing services to a Individual Customer);
 
2. satisfying governmental reporting, tax, and other requirements (e.g., import/export);
 
3. storing and processing data, including Personal Data, in computer databases and
servers located in the United States;
 
4. verifying identity (e.g., for online access to accounts);
 
5. as requested by the Individual Customer;
 
6. for other business related purposes permitted or required under applicable local law and
regulation; and as otherwise required by law.
 

V. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA

 
Except as otherwise provided herein, OpenSesame discloses Personal Data only to Third
Parties who reasonably need to know such data only for the scope of the initial transaction and
not for other purposes. Such recipients must agree to abide by confidentiality obligations.
OpenSesame may provide Personal Data to Third Parties that act as agents, consultants, and
contractors to perform tasks on behalf of and under our instructions. For example, OpenSesame
may store such Personal Data in the facilities operated by Third Parties. Such Third Parties
must agree to use such Personal Data only for the purposes for which they have been engaged
by OpenSesame. 
 
OpenSesame also may disclose Personal Data for other purposes or to other Third Parties
when a Data Subject has consented to or requested such disclosure. Please be aware that
OpenSesame may be required to disclose an individual's personal information in response to a
lawful request by public authorities, including to meet national security or law enforcement
requirements. OpenSesame is liable for appropriate onward transfers of personal data to third
parties.
 
OpenSesame does not share personal data with third parties who do not act as our agents.  If this policy changes in the future, this policy will be updated to reflect that and opt-out choice will be provided to individuals prior to the release of that data.
 

VI. SENSITIVE DATA

 
OpenSesame does not collect Sensitive Data from its Individual Customers.
 

VII. DATA INTEGRITY AND SECURITY

 
OpenSesame uses reasonable efforts to maintain the accuracy and integrity of Personal Data
and to update it as appropriate. OpenSesame has implemented physical and technical
safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure,
alternation, or destruction. For example, electronically stored Personal Data is stored on a
secure network with firewall protection, and access to OpenSesame's electronic information
systems requires user authentication via password or similar means. OpenSesame also
employs access restrictions, limiting the scope of employees who have access to Individual
Customer Personal Data.
 
Further, OpenSesame uses secure encryption technology to protect certain categories of
personal data. Despite these precautions, no data security safeguards guarantee 100% security
all of the time.

 

VIII. NOTIFICATION

 
OpenSesame notifies Individual Customers about its adherence to the EUUS
Privacy Shield and US Swiss Safe Harbor principles through its publicly posted website privacy policy, available at: http://www.OpenSesame.com/privacy and take Individual customers approval and adherence to the current policy when they provide their information to us in the transactional process.

 

IX. ACCESSING PERSONAL DATA

 
OpenSesame personnel may access and use Personal Data only if they are authorized to do so
and only for the purpose for which they are authorized.
 

X. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA

 
1. Right to Access. Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which OpenSesame collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and OpenSesame policies. Upon reasonable request and as required by the Privacy Shield principles, OpenSesame allows Individual Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by logging into their account profile or by contacting OpenSesame by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to local OpenSesame office.
 
2. Requests for Personal Data. OpenSesame will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If OpenSesame receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, OpenSesame will refer such Data Subject to the Individual Customer.
 
3. Satisfying Requests for Access, Modifications, and Corrections. OpenSesame will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

 

XI. CHANGES TO THIS POLICY

 
This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
 

XII. QUESTIONS OR COMPLAINTS

 
EU Individual customers may contact OpenSesame with questions or complaints concerning
this Policy at the following address:
 
 

XIII. ENFORCEMENT AND DISPUTE RESOLUTION

 
In compliance with the USEU Privacy Shield Principles, OpenSesame commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with questions or concerns about the use of their Personal Data should contact us at: support@opensesame.com.
 
If a Customer's question or concern cannot be satisfied through this process OpenSesame has
further committed to refer unresolved privacy complaints under USEU Privacy Shield to an
independent dispute resolution mechanism operated by the Council of Better Business Bureaus.
 
If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by OpenSesame, EU individuals may bring a complaint before the BBB EU Online Privacy Shield. Information about how to file a complaint before the BBB EU Privacy Shield program can be found at www.bbb.org/EU-privacy-shield/for-eu-consumers/.
 
Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
 
OpenSesame commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship. OpenSesame commits to resolve complaints about your privacy and our collection or use of your personal information. Individuals with a question or concern about the use of their Personal Data should contact us at: support@opensesame.com.
 
In compliance with the Swiss US Safe Harbor Principles, OpenSesame commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss individuals with questions or concerns about the use of their Personal Data should contact us at: support@opensesame.com.
 
 
If a Customer's question or concern cannot be satisfied through this process OpenSesame has
further committed to refer unresolved privacy complaints under the US Swiss Safe Harbor to an
independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed please visit:www.bbb.org/us/safe-harbor-complaints for more
information and to file a complaint.

XIV. DEFINED TERMS

 
Capitalized terms in this Privacy Policy have the following meanings:
 
"Individual Customer" means an Individual customer or client of OpenSesame from EU or Switzerland. The term also shall include any individual agent, representative, of an individual customer of OpenSesame and all employee of OpenSesame where OpenSesame has obtained his or her Personal Data from such Individual Customer as part of its business relationship with OpenSesame.
 
"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.
 
"Employee" means an employee (whether temporary, permanent, part time, or contract), former employee, independent contractor, or job applicant of OpenSesame or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.
 
"Europe" or "European" refers to a country in the European Union.
 
"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, email address, user ID, password, and identification numbers. Personal Data does not
include data that is deidentified, anonymous, or publicly available. 
 
For Switzerland, the term "person" includes both a natural person and a legal entity, regardless of the form of the legal entity.
 
"Sensitive Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
 
"Third Party" means any individual or entity that is neither OpenSesame nor an OpenSesame
employee, agent, contractor, or representative.

Policy Changes

 
OpenSesame reserves the right to make, at its sole discretion, any changes, modifications,
additions or deletions to all or portions of this Policy at any time. OpenSesame recommends
that you review this Policy frequently. If OpenSesame makes a material change to this Policy,
OpenSesame will notify you by standard mail or email,or by clear notice on OpenSesame’s
home page. The changes will not be effective against you until the notice has been provided and you have assented to the change through continued use of the Site.

Traveling Beyond the OpenSesame Internet Portal

 
As a trade specific portal, this Site provides you with a doorway to the Internet. When you travel
beyond this Site, OpenSesame advises you to browse carefully. This Policy does not apply to the practices of companies that OpenSesame does not own or control, or to people that OpenSesame does not employ or manage. OpenSesame recommends that you read the Federal Trade Commission reports and discussions regarding privacy and security located at: http://www.ftc.gov/bcp/menus/consumer/tech/privacy.shtm