Berlitz Corporation, a Corporation registered in New York under the number 1382993 , with headquarters located at 7 Roszel Road, Princeton, New Jersey 08540, United States ("Berlitz" or "we") has drafted this Privacy and Cookies Policy (the "Policy") to let you know what kind of information we collect via the Cultural Navigator web application ("Cultural Navigator"), how it is handled, and with whom it may be shared.

This Policy applies only to the processing of personal information carried out by Berlitz Corporation as a data controller with respect to Cultural Navigator. Processing of personal information by Berlitz Corporation as a data controller for other sites - such as Berlitz.com - can be found on those respective web sites. Processing by other affiliated entities or third parties may be governed by separate privacy policies, and we recommend that you review the privacy policies of those entities.

We are committed to handling your personal information in accordance with this Policy, the General Data Protection Regulation ("GDPR"), and other applicable data protection and privacy laws.

Please direct any comments or concerns you may have about this Policy to the contacts listed in the "How Can You Contact Us?" section below.

We collect various types of "personal information" depending upon how you use our websites, such as:

• When you visit our websites, we record your visit in a log file, including the name of each accessed webpage, the date and time of access, the data volume transferred, the operating system used by you, the referrer URL (the previously visited website), your IP address and the access requesting provider. We collect this information in order to ensure website security.
• When you create a Cultural Navigator login, we collect your name, email address, location, and job function. Other information - such as your gender, nationality, or age range - is optional but not required. We collect this information in order to identify you as a customer and deliver services to you.
• When you submit an inquiry, we collect your name and email address in order to process and respond to your inquiries.
• When you use our form for scheduling appointments, we collect your name, email address and other contact details, and selection of language. This information is used to process and handle your request.
• When you indicate that you want to receive marketing emails from us, we collect your name and email address to send you offers and information about our websites, or products, services, and events offered by us or one of our affiliates, including for marketing and promotional purposes (as permitted by law).
• Our purposes and legal bases for processing your personal information are as follows:
  
  

  Purpose of the Processing	Legal Basis
  Recording website visits in a log file	Our legitimate interest, which is the proper functioning of our commercial activity
  Delivering products/services	Performance of our agreement with you and/or your employer
  Managing customer accounts	Our legitimate interest, which is the proper functioning of our commercial activity
  Responding to inquiries	Our legitimate interest, which is the proper functioning of our commercial activity
  Scheduling appointments	Our legitimate interest, which is the proper functioning of our commercial activity
  Sending marketing materials (including offers and other information we feel may be of interest to you)	Your consent

  
  We believe the risk to your data protection rights in connection with personal information that we process on the basis of our legitimate interests is not excessive or overly intrusive. If you choose not to give us personal information we may not be able to provide you with any products or services you may request or require, or enter into a contract with you.
  
  We will only retain your personal information as long as necessary to fulfill the specific purpose or as outlined below:
  
  

  Purpose of the Processing	Applicable Retention Period
  Recording website visits in a log file	7 days, unless it is required for the clarification of or as evidence for specific infringements which have emerged during the retention period.
  Delivering products/services	User Accounts are maintained during the term of service and deleted immediately after expiration, with a grace period of 7 days to restore until permanent purge and deletion from the database. Unexpired User Accounts remaining inactive for a period of 5 years will be deleted.
  Managing customer accounts	User Accounts are maintained during the term of service and deleted immediately after expiration, with a grace period of 7 days to restore until permanent purge and deletion from the database. Unexpired User Accounts remaining inactive for a period of 5 years will be deleted.
  Responding to inquiries	Immediately after user deletion, or 3 years after an inquiry is closed, whichever comes first.
  Scheduling appointments	Immediately after user deletion, or 3 years after the appointment, whichever comes first.
  Sending marketing materials (including offers and other information we feel may be of interest to you)	Immediately after user deletion, or 3 years after the end of our commercial relationship, whichever comes first.

  
  While we continue to process your personal information, we will ensure that it is processed in accordance with this Policy. Otherwise, we securely erase your personal information once it is no longer needed.
  
  When you use Cultural Navigator, we may also collect information that, by itself, cannot be used to directly identify or contact you, such as demographic information or technical information. Such information may also include information that you provide us through your use of Cultural Navigator, such as the terms you enter into the search functions. We use such information to analyze how Cultural Navigator is being used, and to improve the content of our offerings.
  
  Except as specifically set forth in this Policy, we do not share your personal information with any non-affiliated third party without your permission. We may disclose aggregate information, such as demographic information, and our statistical analyses to third parties, including advertisers or other business partners. This aggregate information does not include your personal information. We may, however, share your personal information with certain entities that control us, are controlled by us, or are under common control with us (our "Affiliates"), and websites operated by our Affiliates.We require that our Affiliates agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures. As of October 24, 2018, these Affiliates include the following entities:
  
  
  Berlitz Deutschland GmbH
  
  Berlitz Languages, Inc.
  Berlitz Investment Corporation
  Berlitz Publishing Company, Inc.
  Berlitz Franchising Corporation
  ELS Educational Services, Inc. (ELS)
  World Wide Speaking SARL (World Speaking)
  Second Language Testing, Inc. (SLTI)
  Training Management Corporation (TMC)
  Versation, Inc.
  
  
  We may team with a marketing agency or another website to conduct a sweepstakes or other event. In this case, each of the participating third parties may collect or receive personal information from you if you provide information directly to them. Therefore, you should refer to their privacy policies to understand how they handle your information and what kinds of choices you have.
  
  Berlitz may also share your personal information with outside companies that perform services for Berlitz. For example, we may retain an outside company to manage a database containing certain customer information, to create and distribute an email offering, or to process and respond to your inquiries and requests. When we work with an outside party, we require that these parties agree to process your personal information based on our instructions and in compliance with this Policy. We will take appropriate steps designed to ensure your information will be used solely to provide the services requested by us, and not for other purposes. It is our policy to neither disclose personal information, nor to sell such information to third parties for direct marketing purposes.
  
  Additionally, Berlitz may share your personal information in response to subpoenas, court orders, or other lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information in order to enforce or apply our rights and agreements, or when we believe in good faith that disclosing this information is necessary or advisable, including, for example, to protect the rights, property, or safety of our businesses, our websites, our customers, our users, or others, as permitted under the applicable laws, or as otherwise required by law or by government and regulatory entities. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
  
  Berlitz is committed to doing its best to maintain the security of information collected on our websites. To try to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have implemented physical, electronic, and managerial procedures to safeguard and secure the information we collect.
  
  There is always some risk in transmitting information electronically. As we deem appropriate, we use security measures consistent with industry standards. However, we cannot guarantee the security of our databases, nor can we guarantee that information you supply won-t be intercepted while being transmitted to us over the Internet.
  
  The following section explains rights that you may exercise (where available under applicable law). The various rights are not absolute, and each is subject to certain exceptions:
  
  
  • The right of access - You have the right to obtain from us confirmation as to whether or not your personal information is being processed by us, and about certain other information (similar to that provided in this policy) about how it is used. You also have the right to access your personal information, by requesting a copy of the personal information concerning you, which in most cases will be provided free of charge. This is so you are aware and can check that we are using your information in accordance with applicable data protection and privacy laws. We can refuse to provide information where doing so may reveal personal information about another person or would otherwise negatively impact another person-s rights, or where your requests are repetitive and excessive.
  • The right to rectification (correction) - You can ask us to take measures to correct your personal information if it is inaccurate or incomplete (e.g., if we have the wrong name or address for you).
  • The right to erasure (deletion) - This is also known as the "right to be forgotten" and, in simple terms, enables you to request the deletion or removal of your personal information where, for example, there is no compelling reason for us to keep using it or its use is unlawful. This is however not a general right to erasure and there are some exceptions, e.g., where we need to use the information in defense of a legal claim or to comply with a legal obligation.
  • The right to restrict processing - You have the right to "block" or suppress the further use of your personal information when we are assessing a request for rectification or as an alternative to erasure. When processing is restricted, we can still store your personal information, but may not use it further.
  • The right to data portability - You have the right to obtain and reuse certain personal information for your own purposes across different organizations (being separate data controllers). This only applies to your personal information that you have provided to us that we are processing with your consent and for the purposes of contract fulfillment, which is being processed by automated means. In such a case we will provide you with a copy of your data in a structured, commonly used and machine-readable format or (where technically feasible) we may transmit your data directly to a separate data controller.
  • The right to object - You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of our legitimate interests. We will be allowed to continue to process the personal information if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or we need this for the establishment, exercise or defense of legal claims. If you object to the processing of your personal information for direct marketing purposes, we will no longer process your personal information for such purposes.
  • The right to withdraw consent - Where we process your personal information on the basis of your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that occurred prior to such withdrawal.
  • The right to lodge a complaint - If you believe that we do not comply with applicable data protection laws, you have the right to lodge a complaint before any competent data protection authority. For a list of such authorities, please visit: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.
  
  You may contact us any time at privacy@berlitz.com to exercise these rights.Please note that data which cannot be used to identify you, e.g., data that has been anonymized for analysis purposes, is not affected by the above rights.
  
  It currently is our policy not to knowingly collect personal information from any person under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at privacy@berlitz.com. If we become aware that a child under 13 has provided us with personal information, we will endeavor to delete such information from our files as soon as possible.
  
  If you are under 18 years of age and live in California, you have the right to request removal of content posted by you on our websites. Upon receipt of a fully completed removal request, we will use commercially reasonable efforts to remove content posted by you from our websites. Any such request does not ensure complete or comprehensive removal of your posted content. For example, your posted content may continue to appear on Berlitz-websites if it has been reposted by others or was independently posted by a third party, was posted by you anonymously, or if you were compensated for providing the content. Additionally, while Berlitz will remove the content you posted from our websites, it may continue to be stored on our servers (although it will not be visible to other users of our websites). You must complete the removal request form accurately and in its entirety in order for the request to be processed.
  
  If you are a user under the age of 18 and reside in California, and you wish for your published content to be removed from Berlitz-websites, please provide Berlitz-agent listed below with the following information in a written notice:
  
  
  1. Confirmation that you are currently a legal resident of the state of California;
  2. Confirmation that you are under the age of 18 by providing your birthday;
  3. Describe the exact content that you are seeking to have removed (please provide a URL if possible);
  4. Provide your full name; and
  5. Provide your email address.
  
  Berlitz-designated agent for California Minor Removal Requests can be reached as follows:
  
  
  Service Provider: Berlitz Languages, Inc.
  Name of Agent of Request: Tim Jordan
  By mail: 7 Roszel Road, Princeton, NJ 08540
  By fax: (609) 524-9870
  Email: privacy@berlitz.com (please add "California Minor Removal Request" to the subject line)
  
  
  If you are located outside the U.S., please note that you may be transferring your personal information to a country that does not have the same data protection laws as your home country. For personal information received from the European Union, European Economic Area, United Kingdom, or Switzerland, Berlitz (including its Affiliates listed in the "Affiliated Parties" section above) is committed to handling your personal information in accordance with this Policy and the EU-U.S. Privacy Shield (or the Swiss-U.S. Privacy Shield, as the case may be), as administered by the U.S. Department of Commerce. If there is any conflict between the terms of this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, and to view the certification of Berlitz Languages, Inc., please visit https://www.privacyshield.gov/list.
  
  Berlitz-accountability for personal information that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Berlitz remains responsible and liable under the Privacy Shield Principles if third parties engaged by Berlitz process the personal information in a manner inconsistent with the Principles, unless Berlitz proves that it is not responsible for the event giving rise to the damage.
  
  Please direct any comments or concerns you may have about this Policy to the contacts listed below:
  
  The responsible body for the processing of personal data within the scope of this website and in accordance with the provisions of the General Data Protection Regulation (GDPR) is:
  
  
  Berlitz Corporation
  7 Roszel Road
  Princeton, NJ 08540
  Tel.: +01 609 497-6571
  Web: www.berlitz.us
  Email: privacy@berlitz.com
  
  
  The following is the European representative for the above U.S.-based responsible party:
  
  
  Berlitz Deutschland GmbH
  Hahnstrasse 68-70
  60528 Frankfurt am Main
  Tel.: +49 (0)69 666 08 90
  Web: www.berlitz.de
  Email: info@berlitz.de
  
  
  Our data protection officer is:
  
  
  Henning Strahl, email: datenschutz@berlitz.de
  
  If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
  
  Complaints will be resolved internally in accordance with Berlitz-complaints procedures. If you live in the European Union, European Economic Area, United Kingdom, or Switzerland and efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association ( http://go.adr.org/privacyshield.html ), which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of data originating in the European Union, European Economic Area, United Kingdom, or Switzerland under this Policy. Berlitz is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
  
  When you visit or interact with our websites or services, we (or our authorized service providers) may use cookies or other similar technologies for the functioning of our services, to help us improve our performance, or to give you extra functionalities, all with the goal of providing a better experience. A "cookie" is a small piece of information sent to a visitor-s computer or other Internet-connected devices to uniquely identify the visitor-s browser or to store information or settings in the browser. It holds information a site may need to interact with you and personalize your experience. Cultural Navigator uses two kinds of cookies: required (session) cookies, and analytics and performance cookies.
  
  Required (session) cookies enable you to move from page to page and to use features in Cultural Navigator while your session remains open. These are also referred to as "memory cookies". They are created upon the start of a user session (login) and removed when the session ends (logout) or after 60 minutes of inactivity in the session.
  
  Analytics and performance cookies allow us to collect data concerning Cultural Navigator, including the number of visitors, where the visitors have come from, and the length of time visitors spend on Cultural Navigator, which allows us or third-party service providers to analyze how Cultural Navigator is used and how it is performing. By continuing to use Cultural Navigator after being informed about our use of analytics and performance cookies, you consent to the storing of cookies on your device. This consent is valid for a period of 12 months.
  
  We use Google Analytics which is a service of Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, United States , for analytics and performance tracking, and you can learn more about their privacy policies and how to opt-out of their cookies by clicking on the link below:
  
  
  Google Analytics: http://www.google.com/analytics/learn/privacy.html.
  
  For the provision of its services, Google uses certain cookies and transfers the information generated by such cookies to a Google server in the United States where the information is stored. We use the stored information to analyze your use of our websites, to prepare reports on website activities for website operators, and to provide additional services in connection with the use of our websites. We process such information with your consent. You can object to the collection of your personal information at any time with future effect by applying the Google Analytics deactivation add-on for browsers at: http://tools.google.com/dlpage/gaoptout?hl=de . We would like to point out that this website uses Google Analytics with the "anonymizeIp()" expansion. This means that IP addresses are generally truncated prior to being transferred to the United States, making direct personal identification improbable.
  
  The majority of web browsers accept cookies and similar files, but you can usually change your browser settings to prevent this. If for any reason you decide that you do not like our use of certain cookies, you can simply change your settings. However, if you do so, some functionality of our websites may be lost.
  
  The setting of each browser is different. It is described in the browser-s help menu.
  
  
  • Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
  • Click the access Menu button and then choose "Options"
  • Choose "Privacy & Security"
  • Set the History Section on "Use custom settings for History"
  • Uncheck the box "Accept cookies from websites".
  • All changes you have made will be automatically saved.
  • Internet Explorer: https://support.microsoft.com/en-us/products/windows?os=windows-7
  • Select the Tool button, then Internet Options.
  • Select Privacy Tab, and then under Settings, move the cursor to the top to block all cookies or to the bottom to allow cookies, then click on OK.
  • Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
  • Select the Chrome menu icon.
  • Click on "Settings".
  • At the bottom, click on "Advanced".
  • Under "Privacy and security," click on "Content settings".
  • Click on "Cookies".
  • Turn "Allow sites to save and read cookie data" on or off .
  • Safari: https://www.apple.com/legal/privacy/en-ww/cookies/
  • Click on "Settings" > "Safari" > "Privacy" > "Cookies and website data"
  • Then select "always block cookies".
  
  Changes
  As we continue to develop our websites and take advantage of technologies to improve the services we offer, this Policy will likely change. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to refer to this Policy on an ongoing basis, so that you understand our current Policy. This Policy was last updated February 6, 2020.