This Safe Harbor Notice (the “Notice”) sets forth the privacy principles followed by RT (hereafter referred to as RT) in connection with the transfer and protection of “personal information” received from the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.
About the Safe Harbor
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles (the “U.S.-EU Safe Harbor Principles”) and frequently asked questions (collectively the “U.S.-EU Safe Harbor Framework”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. The EEA also has recognized the U.S. Safe Harbor as providing adequate data protection. The United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of data protection principles (the “U.S.-Swiss Safe Harbor Principles”) and frequently asked questions (collectively the “U.S.-Swiss Safe Harbor Framework) to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States. Consistent with its commitment to protect personal privacy, RT adheres to the U.S.-EU and U.S.-Swiss Safe Harbor Principles (hereinafter “Safe Harbor Principles”).
“Personal Information” means information that can directly or indirectly lead to the identification of a living person, such as an individual’s name, address, e-mail, telephone number, license number, medical identification number, photograph, or other identifying characteristic. The identification can occur by reference to one or more factors specific to the individual’s physical, physiological, mental, economic, cultural or social identity.
RT does not own data entered into the service by our customers, and processes such data only in accordance with the instructions of its customers. In accordance with the Safe Harbor Principles, RT works with its customers to ensure privacy protection and clear notices to individuals about their personal data and their rights under the Safe Harbor framework.
Safe Harbor Privacy Principles
The following privacy principles apply to the transfer, collection, use or disclosure of personal information form the EEA by RT.
Notice: Where RT collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them and the choices and means, if any, RT offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to RT, or as soon as practicable thereafter, and in any event before RT uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a non-agent third party.
Where RT receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
Consistent with the Safe Harbor requirements, RT may not be in a position to furnish notice in certain limited situation. Specifically, notice is not required where the processing of EEA personal information is necessary to respond to a government inquiry; is required by applicable laws, court orders or government regulations; or is necessary to protect RT legal interests and providing notice would interfere with those interests.
Choice: RT will not process personal information about EEA individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the EEA individual unless the individual affirmatively and explicitly consents (“opt-in”) to the processing, or unless an exception applies. RT also provides EEA individuals with the opportunity to withdraw consent at any time (“opt-out”), in which case their personal information will not be further processed.
RT will provide individuals with reasonable mechanisms to exercise their choices.
Data Integrity: RT seeks to ensure that any personal information held about EEA individuals is accurate, complete, current and otherwise reliable in relation to the purposes for which the information was obtained. RT collects personal information that is adequate, relevant and not excessive for the purposes for which it is to be processed. EEA individuals have a responsibility to assist RT in maintaining accurate, complete and current personal information about them.
Transfers to Third Parties: RT will not transfer personal information about EEA individuals to 3rd parties unless the 3rd party (a) has provided satisfactory assurance to RT that it will protect the information consistently with this Notice; or (b) is located in the EEA or a country considered “adequate” for privacy by the EU Commission, and therefore is required to comply with the EU data protection laws or substantially equivalent privacy laws; or (c) the 3rd party has also certified to the Safe Harbor, and is accordingly independently responsible for complying with the Safe Harbor requirements.
Where RT has knowledge that a 3rd party to whom it has provided EEA personal information is processing that information in a manner contrary to this Notice or the Safe Harbor requirements, RT will take reasonable steps to prevent or stop the processing.
Access and Correction: Upon written request to RT, RT will provide EEA individuals with reasonable access to their personal information. RT will also take reasonable steps to allow EEA individuals to review their information for the purposes of correction their information. There are certain limitations to the Access and Correction rights, as set forth in the US Department of Commerce’s Safe Harbor website – http://www.export.gov/safeharbor/.
These requests can be made by completing our Message form at
or by calling RT office at the number listed at
Security: RT takes reasonable precautions to protect EEA personal information in its possession from loss, misuse, unauthorized access, disclosure, alteration and destruction.
Enforcement: RT has established internal mechanisms to verify its ongoing adherence to this Notice. Any employee that RT determines intentionally violates this policy will be subject to disciplinary action up to and including termination of employment.
Dispute Resolution: RT also encourages individuals covered by this Notice to raise any concerns about our processing of their personal information by contacting RT at the address below or by contacting their local privacy officer. RT will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between RT and the complainant, RT has agreed to participate in the dispute resolution procedures of the American Arbitration Association pursuant to the Safe Harbor Principles.
Limitation on Scope of Principles: Adherence by RT to these Safe Harbor Principles may be limited (a) to the extent required or permitted by law or legal process, such as to respond to or investigate a legal or ethical obligation or request or pursuant to court orders, subpoenas, interrogatories or similar directive carrying the force of law; and (b) to the extent expressly permitted by an applicable law, rule or regulation.
Contact Information: Questions or comments about this Notice should be directed to:
Rebellion Training, LLC
5475 Reno Corporate Drive, Suite 500
Reno, Nevada 89511 (USA)