Effective Date: 20th of June 2018
PetroSkills[WU1] and its affiliates provides a complete spectrum of solutions, courses, and learning tools (the “Services”) to develop competent petroleum professionals. In order to provide these Services PetroSkills collects personal information through online and offline transactions. Your privacy is important to us. This notice outlines PetroSkills’ general privacy and security practices with respect to personal information. While this policy sets forth our general privacy and security practices, the detailed obligations and commitment of PetroSkills is set forth in the contractual arrangements with our customers. In the event of a conflict between this policy and a contract with the customer, the contract prevails.
The Information We Collect
This notice applies to all information collected by or submitted to PetroSkills. The types of personal information collected are:
- Company & Job Title
- Email address
- Phone number
- Country of citizenship
- Credit/Debit Card Information
The Way We Use Information
We use the information you provide about yourself or someone else to ensure we provide you with the products and services that you purchase from us. If you do not supply this information we may not be able to provide you with the requested products or services. The information may be used to perform a variety of purposes/activities:
- Provide and deliver the services and features you request, process and complete transactions, and send you related information, including purchase confirmations and invoices;
- Respond to your comments, questions, and requests and provide customer service and support;
- Communicate with you about services, features, surveys, newsletters, offers, promotions and events, and provide other news or information about PetroSkills;
- Monitor and analyze trends, usage, and activities in connection with the PetroSkills Services and for marketing or advertising purposes;
- Investigate and prevent fraudulent transactions, unauthorized access to PetroSkills Services and other illegal activities;
- Personalize and improve the PetroSkills Services and provide content, features, catalogs and/or advertisements that match your interests and preferences or otherwise customize your experience using PetroSkills Services;
- For other purposes about which we notify you;
- To improve our services and marketing effectiveness. For example, we use non-identifying and aggregate information to note that X number of individuals took a certain course, or that Y number of individuals from a certain region used our services.
Legal Basis for Processing EU Personal Information
Personal information of EU data subjects must be processed fairly and lawfully. In order to do so, the processing must be based on one or more specific legal grounds. The most relevant legal grounds for processing personal data include:
- The data subject having unambiguously given his or her consent.
- The processing is necessary for the performance of a contract to which the data subject is a party (e.g., a service agreement) or in order to take steps at the request of the data subject prior to entering into a contract.
- The processing is necessary for PetroSkills to comply with an EU/Member State legal obligation applicable to PetroSkills.
- The processing is necessary for the purpose of legitimate interests pursued by PetroSkills unless such interests are overridden by the rights of the data subject. In making such a determination, PetroSkills will conduct a legitimate interest assessment.
Where consent is the ground being relied on this must be freely given, specific, informed and unambiguous indication of the data subject's wishes. The data subject must provide an active indication that he or she agrees to the processing of his or her personal data. The consent shall be in writing or other legally permissible means. The data subject has the right to withdraw consent at any time by contacting PetroSkills at Privacy@PetroSkills.com.
PetroSkills participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework’s applicable Principles. To learn more about each Privacy Shield Framework and to view our certification, visit the U.S. Department of Commerce Privacy Shield List. https://www.privacyshield.gov/list (link is external)
PetroSkills is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. PetroSkills complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, PetroSkills is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, PetroSkills may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We will investigate and attempt to resolve any complaints or disputes regarding the use of your Personal Data within a reasonable period of time of receiving your complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, refer to the Complaint, Enforcement, and Dispute Resolution section below for further details.
Under certain conditions, more fully described on the Privacy Shield website (link is external), you may invoke binding arbitration when other dispute resolution procedures have been exhausted (see Section 14 below for additional details concerning dispute resolution).
International Data Transfers
PetroSkills transfers EU personal data to the United States and other jurisdictions across the globe. As noted above, for transfers to the United States and any onward transfers of that data, PetroSkills relies on the EU-US and Swiss-US Privacy Shield Frameworks. For transfers of personal data from the EU to other jurisdictions, PetroSkills relies on one of the following:
- Article 45 determination of adequacy
- One of the Article 46 safeguards including standard contractual clauses
- One of the Article 49 derogations including explicit consent of the data subject
Data Integrity and Purpose Limitation
We do not process personal information in a way that is incompatible with the purpose for which it has been collected or subsequently authorized by the individual. With respect to visitors to our websites, we only collect information that we believe to be relevant to our business. With respect to data that we process on behalf of our customers, we only process personal information to the extent that such processing is necessary for providing our services, and in accordance with our agreements with our customers. In all instances of data collection or receipt, we take reasonable steps to ensure that personal data we collect or receive from our customers is reliable for its intended use.
Sharing and Disclosing of Information
We will not share personal information about you or any content with any third parties except as described in this Privacy Notice or in connection with PetroSkills Services. For example, we may share personal information about you in the following situations:
Vendors, Consultants and Other Service Providers: We may share your information with third-party vendors, consultants and other service providers who are working on our behalf and require access to your information to carry out that work, such as to process billing, provide customer support, etc. These service providers are authorized to use your personal information only as necessary to provide services to PetroSkills and/or PetroSkills Services.
Employer: If requested, we may share your contact information, information about the products or services that you purchased, critiques and/or evaluations that you submitted.
Compliance with Laws: We may disclose your information to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and Terms of Service, (c) to protect the security or integrity of the PetroSkills Services, (d) to protect PetroSkills, our customers or the public from harm or illegal activities.
Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Aggregated or Anonymized Data: We may also share aggregated or anonymized information with third parties that does not directly identify you.
PetroSkills maintains a third-party risk management program to ensure that third-parties have acceptable security and privacy controls in place before accessing or handling any data on behalf of PetroSkills.
Our Commitment to Data Security and Retention
No method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. PetroSkills Customers are responsible for maintaining security and confidentiality of their usernames and passwords.
Your personal information is stored and retained by PetroSkills for the duration of our relationship with you. PetroSkills only retains the data for as long as necessary based on the defined business purpose and/or legal and compliance obligations.
For any concerns or more information regarding security and/or where or how long your personal data is stored, please contact Privacy@PetroSkills.com
Customer Data – Hosted Software Services
PetroSkills SaaS systems collect information under the direction of its customers and has no direct relationship with the individuals whose personal data it processes. If you are an individual of one of our SaaS customers and would no longer like to be contacted by one of our customers that use our service, please contact the customer that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers. The use of information collected through our SaaS solution shall be limited to the purpose of providing the service for which the customer has engaged PetroSkills.
We will retain your information as needed to provide you products and services. We will retain and use your information to comply with our legal obligations, resolve disputes and fulfill our agreements.
Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie. Please note, if you choose to remove or reject browser cookies, this could affect the functionality of the PetroSkills Services. Cookies or similar technologies may be used for the following purposes:
- To analyze trends, statistics and patterns
- To help provide better customer service
- To better serve you when you re-visit a webpage
- To monitor the regions from which visitors navigate our web sites
- To provide you with advertising based upon your browsing activities and interests
Your Data Subject Rights When We Act as a Data Controller
Where required by contract with our customers, or where applicable law applies, PetroSkills will provide you, at your request, with information about whether we hold any of your personal information. You have the right to provide PetroSkills with updated information should you discover inaccurate information on file. You have the right to request the erasure of your personal information, subject to certain exceptions. You may also have the right to request that PetroSkills cease to use your personal data for the purpose of direct marketing. Where technically feasible, PetroSkills will, at your request, provide your personal data to you or transmit it directly to another controller.
We will respond to your request within a reasonable timeframe. In certain circumstances, we may be required by law to retain your personal information or may need to retain your personal information in order to continue providing a service. If you have concerns about the way PetroSkills is processing your personal data, in some jurisdictions you have the right to lodge a complaint with the appropriate data protection authority.
Your Data Subject Rights When We Act as a Data Processor
Where required by contract with our customers, or where applicable law applies, PetroSkills acknowledges that you have the right to access your personal information. PetroSkills has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to PetroSkills’ Client (the data controller). If requested to remove data, we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information or may need to retain your personal information in order to continue providing a service.
Complaint, Enforcement, and Dispute Resolution
In the unlikely event that customers have suffered harm due to a breach of their rights under the data protection policy and PetroSkills has not handled the complaint in a sufficient manner, customers may lodge a complaint with the supervisory authority.
PetroSkills has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, The International Centre for Dispute Resolution (ICDR), International Division of the American Arbitration Association (AAA). If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.icdr.org/privacyshield.
PetroSkills is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. There is the possibility, under certain circumstances, for EU and Swiss individuals to invoke additional binding arbitration.
PetroSkills retains sole and absolute discretion in resolving all questions relating to the administration, interpretation and application of this policy. This authority includes construing the terms of this policy, including any disputed or doubtful terms.
Our services are not intended for or to attract children. Accordingly, we do not solicit nor knowingly collect any personal information from children under the age of thirteen (13). If we learn that personal information is, has been submitted by, or collected from a child under the age of thirteen (13), we will immediately delete such information.
PetroSkills performs ongoing monitoring of privacy and security controls to validate compliance with applicable laws and regulations.
Who Will Contact You
- You may receive email from the following addresses at PetroSkills: Privacy@PetroSkills.com, Accounting@PetroSkills.com, Customer.Service@PetroSkills.com, Support@petroskills.com and Promotions@PetroSkills.com.
How To Contact Us
- Any questions about this Privacy Notice should be addressed to Privacy@PetroSkills.com, or to Attn: Privacy Manager PetroSkills, 2930 S. Yale Ave, Tulsa, OK 74114.
[WU1]Verify scope of legal entities to be covered by notice.