Last updated: June 06, 2017
1. Pokeshot SmarterPath Privacy Statement
Pokeshot GmbH is committed to protecting your privacy. This privacy statement applies to the data collected by Pokeshot GmbH through use of Pokeshot SmarterPath services (the “Service” or “Services”); it does not apply to other online or offline Pokeshot GmbH sites, products, or services.
2. Pokeshot SmarterPath Apps
"Pokeshot SmarterPath" refers to the end user facing component of the service.
3. User’s Customer Data
Customer Data is all the data, including all text, sound, software or image files that you provide, or are provided on your behalf, to us through your use of the Services. We make no claim of ownership to your Customer Data. Except as provided in this privacy statement or described in your agreements, we only use Customer Data to provide and enhance the Services. We don’t share your Customer Data with advertisers, or with anybody else except in the very limited circumstances described in the Sharing Your Information section below.
You find an overview of the specific data used in SmarterPath in our Meet the GDPR within your Organization - How SmarterPath supports you documentation. The data is store in Microsoft Azure. Detailed information is available in the Windows Azure PrivacyOverview.
4. Contact Data
Contact Data includes name, email address and global user id that we may collect through your administration of the Services and use of the Services by you and others. Contact data beyond the global user id is only collected when you contact us through the support or license enablement functions in Pokeshot SmarterPath. We may also use Contact Data to contact you to provide information about new subscriptions, billing and important updates about the Services, including information about security or other technical issues. We may also contact you regarding third-party inquiries as described in this privacy statement or your agreement(s). If you are a verified administrator for the Service, you may not be able to unsubscribe from some of these communications. Subject to your contact preferences, we may also use Contact Data to contact you regarding information and offers about the Service, other products and services or to request your feedback.
5. Usage Data
We may use statistical data, analytics, trends and usage information derived from your use of the Services (“usage data”). Usage data includes, for example, aggregated quantitative information about active users, trainings, learner progress, and groups. Some of the ways we use the usage data include operating, improving and personalizing the Services and our offerings. Except to provide reports to you or others in your organization, we do not disclose usage data in a way which is identifiable to your organization or users in Pokeshot SmarterPath.
6. Support Data
Support Data is the information we collect when you submit a support request or run an automated troubleshooter, including information about hardware, software, and other details related to the support incident, such as: contact or authentication information, chat session personalization, information about the condition of the computer and the application when the fault occurred and during diagnostics, system and registry data about software installations and hardware configurations, and error-tracking files. Support may be provided through phone, e-mail, or online chat. We may use Remote Access (RA), with your permission, to temporarily navigate your desktop. Phone conversations, online chat sessions, or RA sessions with support professionals may be recorded and/or monitored. For RA, you may also access the recording after your session. For Online Chat or RA, you may end a session at any time of your choosing. We use Support Data in the same way as we use your information, as described in this privacy statement. Additionally, we use it to resolve your support incident and for training purposes. Following a support incident, we may send you a survey about your experience. You must opt-out of support surveys separately from other communications provided by Pokeshot, by contacting Support or by using the link provided in the footer of the survey e-mail. To review and edit your personal information collected through our support services, and for any other inquiries regarding our support services, please contact us by using the email address:
Some business customers may purchase enhanced support offerings (e.g. Enterprise Plus etc.). These offerings are covered by their own contract terms and notices.
7. Sharing Your Information
We will not disclose Customer Data or Contact Data (“your information”) outside of Pokeshot GmbH or its controlled subsidiaries and affiliates except as you direct, or as described in your agreement(s) or this privacy statement.
We don’t share any of your information with advertisers.
We occasionally contract with other companies to provide services (such as customer support, data management, and technical infrastructure services) on our behalf. We may provide these companies with access to your information where necessary for their engagement. These companies are required to maintain the confidentiality of your information and are prohibited from using it for any purpose other than that for which they are engaged by Pokeshot GmbH.
We will not disclose your information to a third party (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) except as you direct or unless required by law. Should a third party contact Pokeshot GmbH with a request for your information, we will attempt to redirect the third party to request the data directly from you. As part of that process, we may provide your basic contact information to the third party. If legally compelled to disclose your information to a third party, we will use commercially reasonable efforts to notify you in advance of a disclosure unless legally prohibited.
Pokeshot GmbH may share Contact Data with third parties for the purposes of fraud prevention or to process payment transactions, as further described in this statement.
We will not substantively respond to data protection and privacy requests from your users without your prior written consent, unless required by applicable law.
We have implemented and will maintain appropriate technical and organizational measures, internal controls, and information security routines intended to protect your information against: accidental loss, destruction, or alteration; unauthorized disclosure or access; or unlawful destruction. If you choose to host videos in Pokeshot SmarterPath for streaming and CDN support, these videos are accessible using a random URL. These URLs cannot easily be guessed as they contain at least two globally unique identifiers (GUIDs), but they are public.
You can find an overview of our general security measures in our Pokeshot General Security Overview and a detailed reference to our Application Security in our SmarterPath Application Security document.
9. Data Location
Your Services’ data may be transferred to, stored and processed in the United States, Germany or any other country where Pokeshot GmbH or its affiliates, subsidiaries or service providers maintain facilities. Customer can choose whether they want data to be stored in one of the following countries: United States, the Netherlands or Singapore.
10. Changes to this Privacy Statement
We will occasionally update this privacy statement to reflect customer feedback, changes in our Services, and updates to applicable data privacy laws and regulations. When we post changes to this statement, we will revise the “last updated” date at the top of the statement. If there are material changes to this statement or in how Pokeshot GmbH will use your information, we will notify you by either posting a notice of such changes before they take effect or by direct notification. We encourage you to periodically review this privacy statement to learn how Pokeshot GmbH is protecting your information