Last updated: October 11, 2023
This Privacy Notice outlines Blue Sky eLearn’s policies and practices regarding the collection and use of your personal data, as well as describes your privacy rights. This Privacy Notice covers the following websites as applicable:
“Data Subjects” refers to individuals whose personal data is processed or controlled by an entity or organization. These individuals have rights, as granted by applicable laws and regulations, including the right to access, correct, restrict, or erase their personal data. Upon receiving a valid request from a data subject, the responsible entity or organization takes appropriate steps to comply with the request in a timely manner, while considering any legal, regulatory, or contractual obligations.
We diligently consider and document our legal basis for processing personal data, ensuring that our processing activities align with applicable data protection laws, regulations, and the provisions specified in the DPA. We prioritize the protection of individual rights and freedoms while fulfilling our obligations and pursuing our legitimate business interests.
Some areas of the site may collect contact information, such as your name, email address or information related to the organization for which you work.
The website collects the following information automatically:
Blue Sky eLearn uses your personal information for the purposes for which you voluntarily provided it to us. For example, inquiries into a particular product or service, we will use your data to provide you with the requested information or service. We also may collect data concerning your use of this website, such as where you visited from, pages visited, or links clicked. This data is collected for analytics purposes.
Blue Sky eLearn receives minimal business information from our customers or voluntarily from end users for business use only:
Blue Sky eLearn either collects data from our customers or it is voluntarily submitted by end users. Data collected is limited to the minimal business information required to utilize our training platform and communications tools to provide a service. Personally identifiable information includes Name, Email Address, Phone, and other pertinent information used for training assignments.
The Platform collects the following information automatically:
Blue Sky eLearn takes reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current.
We may also learn information about you as part of your use of social media on our site. For example, we may have a “like” or “tweet” or similar button that includes a link to our social page to help you generate a social media posting by you on Facebook, LinkedIn, Twitter or other platform that highlights or points back to the content on our site that you liked, tweeted, etc. If you use the social media features on our website we will capture data regarding your organizational affiliations or workplace, professional role and professional social network.
We publish sites on social media services, such as LinkedIn, Facebook, Instagram, Google MyBusiness and Twitter. If you interact with our site or posts we will capture the information you volunteer about yourself as well as information available to social media users generally.
You should review the privacy policies of the social media providers as well since your visit to their platform by means of our social media button may allow them to collect information about your activity on our site.
Depending on the circumstances, examples of compatible processing purposes may include those that reasonably serve customer relations, compliance and legal consideration, auditing, security, fraud prevention, preserving or defending the organization’s legal rights or other purposes consistent with the expectations of a reasonable person given the context of the collection.
Blue Sky eLearn uses data received from customers and collected from customers in connection with eLearning services for:
Blue Sky eLearn does not use data collected for purposes that are materially different from the purposes for which it was originally collected or subsequently authorized by the individuals.
Blue Sky eLearn does not knowingly collect, store, or process personal data from individuals under the age of 18. If we become aware that we have collected personal data from a child under the age of 18, we will take steps to delete that information as quickly as possible.
Blue Sky eLearn is committed to retaining personal data only for as long as it is necessary to fulfill the purposes for which the data was collected, in accordance with applicable legal, regulatory, and contractual obligations. Our data retention practices adhere to the following principles:
By implementing these data retention principles, Blue Sky eLearn ensures that personal data is managed responsibly, securely, and in line with the privacy expectations of our users and the requirements of applicable data protection laws.
Blue Sky eLearn adheres to the DPF Principles for all personal data received from the EU, United Kingdom, and Switzerland in reliance on the DPF.
Blue Sky eLearn is committed to providing individuals with choices and control over their personal data. We offer various opt-out mechanisms and data access options to help users manage their personal information effectively. Our opt-out and data access procedures are designed to be user-friendly, transparent, and in line with the requirements of applicable data protection laws. The following options are available to users:
To submit a data subject request or for further assistance with opt-out choices and data access options, please contact our Privacy team at firstname.lastname@example.org.
In the event of a personal data breach, Blue Sky eLearn, as the data controller, will promptly assess the nature and scope of the breach in accordance with the Data Protection Agreement (DPA). We will work in conjunction with the data processor to take immediate and necessary steps to contain and mitigate the impact of the breach, as specified in the DPA.
If the breach poses a significant risk to the rights and freedoms of individuals, we will fulfill our obligations under the DPA and promptly notify the affected individuals and relevant supervisory authorities, as required by applicable laws and regulations. The notification will include, to the extent known or reasonably ascertainable, the relevant details of the breach, its potential consequences, and the measures taken or proposed to betaken to address the breach.
Blue Sky eLearn will collaborate closely with the data processor, as outlined in the DPA, to provide any necessary cooperation and assistance to the affected individuals and supervisory authorities, enabling them to comply with their respective obligations under the General Data Protection Regulation (GDPR) or other applicable data protection laws.
Our breach notification process, as set forth in the DPA, ensures transparency, accountability, and compliance with data protection requirements. We maintain appropriate records of all personal data breaches, including the facts surrounding the breach, its effects, and the remedial actions taken, as required by the DPA and applicable regulations.
Blue Sky eLearn does not disclose personal information to third parties for purposes that are materially different than what it was originally collected for. Blue Sky may provide personal data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. Third Parties agree to provide adequate protections for the personal data that are no less protective than those set out in this Policy.
Blue Sky eLearn remains liable for onward transfers of personal data to third parties acting as our agents unless otherwise agreed with the data exporter. Blue Sky eLearn is responsible for the processing of personal data we receive and subsequently transfer to a third party acting as an agent on our behalf. Blue Sky eLearn does not currently transfer personal data received under the EU-U.S. DPF to any third parties acting as processors or controllers.
However, if Blue Sky eLearn does transfer such personal data to third parties in the future, we shall remain liable under the DPF Principles if the third party processes the data in a manner inconsistent with the DPF Principles, unless Blue Sky eLearn proves it is not responsible for the event giving rise to the damage.
Under the California Consumer Privacy Act (CCPA), as amended, California residents are granted specific rights regarding their personal information. Blue Sky eLearn is committed to upholding these rights and ensuring transparency in our data handling practices. This Rights of California Residents provision outlines the rights granted to California residents and the steps required to exercise those rights.
Blue Sky eLearn is committed to ensuring the privacy and protection of your personal information. As part of our expanded notification requirements, we want to inform you about the data retention practices and the collection of specific categories of sensitive personal information (SPI). Please read the following provisions carefully:
At Blue Sky eLearn, we are committed to upholding the highest standards of privacy and security for our global customers and end users. As part of this commitment, we diligently adhere to the European Union's General Data Protection Regulation (GDPR) to ensure the protection and proper handling of our customers' and end users' personal data. As a GDPR-compliant organization, we have implemented the necessary tools and processes to support our clients who are required to follow the regulation, enabling them to fulfill their respective responsibilities under the GDPR.
We prioritize the privacy and security of our customers' and end users' personal data, maintaining robust technical and organizational security measures to safeguard the information entrusted to us. Our state-of-the-art platforms are hosted on secure cloud hosting providers that are SOC 1 & 2, SSAE 18/ISAE 3402, ISO 27001, and PCI Level 1 compliant. These advanced hosting providers adhere to the latest industry standards to guarantee the highest level of data protection.
Our multi-layered security approach includes implementing active perimeter security measures and working with reputable third-party organizations to conduct vulnerability scans and assessments, ensuring that potential risks are effectively mitigated. We continuously review and update our security policies and practices to ensure alignment with evolving industry best practices and regulatory requirements. Additionally, we provide ongoing training to our personnel to guarantee awareness of, and compliance with, our stringent data security measures.
To learn more about our cyber security efforts, please review our Cyber Security Policy.
In accordance with the GDPR requirements, Blue Sky eLearn is pleased to offer our customers a comprehensive and GDPR-compliant Data Processing Addendum (DPA). Our DPA is designed to provide clear instructions and assurances about the handling and processing of personal data, ensuring transparency and compliance with the GDPR guidelines.
Key elements of our GDPR-compliant Data Processing Addendum include:
To view our Data Processing Addendum, please click here. If you have any questions or concerns, please don't hesitate to reach out to our dedicated privacy team.
In the course of providing our services, Blue Sky eLearn engages various sub-processors to access and process personal data on our behalf. These sub-processors have been carefully selected to ensure that they maintain the highest standards of data privacy and security. A current list of our sub-processors, along with their respective countries, sub-processor activities, and products or services involved, can be found on our Sub-Processors page here.
In accordance with the EU General Data Protection Regulation (GDPR), Blue Sky eLearn is dedicated to protecting and upholding the individual rights of our users. These rights include:
Rights related to automated decision-making and profiling: Users have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning them or similarly significantly affects them. Blue Sky eLearn does not engage in automated decision-making that would result in such consequences.
Blue Sky eLearn acknowledges the importance of ensuring the lawful and secure transfer of personal data across international borders. This International Data Transfers provision outlines our approach to safeguarding personal information when transferred outside its originating country, in compliance with applicable data protection laws and regulations.
Blue Sky eLearn is committed to providing an inclusive and accessible learning experience for all users, ensuring that our products and services cater to a wide range of needs and abilities. In line with this commitment, our platforms are designed and developed in accordance with internationally recognized accessibility standards, including Section 508 and the Web Content Accessibility Guidelines (WCAG) 2.0 AA.
Our Accessibility Compliance provisions include the following:
Click here to access the VPAT report.
If you have any questions, concerns, or suggestions regarding our Accessibility Compliance, please feel free to contact us.
Individuals have a right to access their personal data. Individuals may access their profile data on Blue Sky eLearn Applications by logging into their profile utilizing their assigned unique ID and password. All individuals may also contact us directly to access their data by emailing email@example.com.
Individuals may email Blue Sky eLearn with questions / comments regarding information correction, amendment, deletion, and limiting use and disclosure at: firstname.lastname@example.org.
In compliance with the EU-U.S. DPF, Blue Sky eLearn commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF should first contact Blue Sky eLearn at:
Blue Sky eLearn
5405 Morehouse Drive, Suite 340
San Diego, CA 92121
Or by email: email@example.com
In compliance with the EU-U.S. DPF, Blue Sky eLearn commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF to JAMS DPF Program, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-data-privacy-framework for more information or to file a complaint. The services of JAMS DPF Program are provided at no cost to you.
Under certain conditions, EU individuals have the possibility to invoke binding arbitration to address complaints regarding Blue Sky eLearn's compliance with the EU-U.S. DPF Principles. This arbitration option is available for complaints not resolved by other DPF mechanisms. For additional information on when and how binding arbitration can be invoked, please see Annex I of the EU-U.S. DPF Principles: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2
Blue Sky eLearn does not collect Sensitive Data from its customers.
Blue Sky eLearn is subject to the jurisdiction of the Federal Trade Commission and other authorized U.S. statutory bodies.
Blue Sky eLearn may disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Blue Sky eLearn uses reasonable efforts to maintain the accuracy of personally identifiable information and to keep it updated as required. Blue Sky eLearn has implemented physical and technical measures to protect customer data from misuse, loss, and unauthorized access.
In addition, Blue Sky eLearn uses secure encryption technology to protect certain categories of personal data. Even with these precautions, no data security safeguards guarantee 100% security all the time.
To learn more about our cyber security efforts, please review our Cyber Security Policy.
Questions or comments regarding this Policy should be submitted to Blue Sky eLearn by mail to:
Blue Sky eLearn
5405 Morehouse Drive Suite 340
San Diego, CA 92121
Or by email: firstname.lastname@example.org