Privacy Statement Updated January 4, 2019.
Welcome to Say Travel Consulting Inc. (STC) and its affiliated organizations. STC is the leading global authority in the field of healthcare, medical travel, wellness, benefits,and insurance.
Your use of the STC Websites and/or provision of your personal information or sensitive personal information to STC constitutes your consent to the use, storage, processing and transfer of that information in accordance with this Privacy Statement. For the purposes of the EU General Data Protection Regulation 2016⁄679 (the “GDPR”) the data controller is Say Travel Consulting Inc. with an office 8845 N. Military Trail, Suite 300, Palm Beach Gardens, FL 33410. STC is an organization based in the United States. Where your data is being collected and used by Say Travel Consulting Inc., all references to STC herein shall mean STC or affiliated companies or associations STC manages.
If you have any questions or complaints regarding this Privacy Statement, please contact us at email@example.com. If you have any questions about the STC Websites, please contact us at firstname.lastname@example.org, by phone at 1-416-464-7151, or send a letter to:
Say Travel Consulting Inc. 80 Cosburn Avenue unit 803 Toronto, On. Canada M4K 2G6
CHANGES TO THIS PRIVACY STATEMENT
• What information do we collect? • What are “cookies” and how does STC use them? • Do we share information with third parties? • How do we use the information we collect? • How can you review and modify your personal information? • What is the opt-out policy for STC Websites? • Your Ontario • privacy rights • Your European privacy rights • What types of security procedures are in place to protect against the loss, misuse or alteration of your information? • How do STC Websites use bulletin boards, discussion lists, and moderated chats?
1. What information do we collect?
STC Websites collect the following personal information about site visitors:
a) Site Use Information
STC collects technical information relating to each time a visitor comes to a STC Website, including IP address, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform type (e.g. Internet Explorer browser on a Windows platform). We may also collect information about your visit, including pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number. Gathering this technical information helps us to learn what browsers we need to support and helps us determine what sections of STC Websites are most popular and how many visitors come to our site(s). You do not have to register with STC Websites before we can collect this information.
b) Information You Give Us
You may provide personal information to us which may include your name, home and/or work email address, postal address, phone number and/or fax number, your employer and job title, demographic information about you including birth year, certification designation, etc., and if you are making a purchase, your credit card information. You are only required to provide such information if you want to take advantage of optional products and services provided through STC Websites. STC collects personal information in the following ways from different parts of the STC Websites:
• STC or Association Membership Applications: You are sharing personal information with us when you join a STC managed association or renew your membership through the STC Websites. STC or association members will have STC or association membership log-in credentials which enable members to take advantage of restricted content and features on STC Websites. • Other Registration: When registering for specific services we may ask for the same type of personal information. For example, if you subscribe to an e-mail newsletter, we will ask you to provide your e-mail address. • Online Purchases: When you make a purchase using the STC store(s) or when you subscribe to a STC publication through the STC websites we may also ask for the same type of personal information. The number and variety of useful services on STC Websites that may require the collection of personal information about you will continue to grow in the future.
2. What are “cookies” and how does STC use them?
3. Do we share information with third parties?
Personal information collected through STC Websites is generally collected and maintained solely by STC or its contracted vendors. We may share personal information in the following ways:
a) Information You Give Us
Personal information provided when you register for services or products. When you provide personal information about you on STC Websites to register for a service, buy a product, or take advantage of a promotion STC reserves the right to sell or otherwise provide to selected third parties, mailing/information lists derived from such registrations. If you wish to opt out of such list sales/distribution at any time, you may do so by following the directions in Item 6 below. We will not share personal information relating to individuals based in the EU unless you have provided your opt in consent.
Information provided when joining or renewing membership in a STC managed association. If you join STC or a STC managed association or renew your membership through the STC Websites, you provide personal information about you on the membership application. STC reserves the right to sell or otherwise provide mailing/information lists concerning members to selected third-parties. If you wish to opt out of such list sales/distributions at any time during your STC membership, you may do so by following the directions in Item 6 below. We will not share personal information relating to individuals based in the EU unless you have provided your opt in consent. STC does not sell to third-parties, e-mail addresses obtained from member applications or renewals (except that STC will rent a member e-mail address if that member has expressly opted in to allow such rentals).Sensitive Personal Information. STC does not share with third parties, sensitive personal information such as passcodes, social security numbers, credit card numbers, felony conviction information, or health information except as necessary to complete transactions requested by you and under strict confidentiality and security protections; nor does STC publish such sensitive personal information.
b) Site Use Information
We disclose to third-party sponsors/advertisers aggregate statistics (i.e. impressions and click-throughs on a company’s advertisement). In addition, we may share aggregate website statistics with the media or other third parties. We do not disclose personal information to these sponsors/advertisers or other third parties as part of this process, only information in an aggregate form.
c) STC Subsidiaries
4. How do we use the information we collect?
a) Information You Give Us
We use the personal information you give us: 1. to carry out our obligations arising from your membership and any other agreement entered into between you and us 2. to update and renew your membership as required 3. to provide you with the information, products and services you request from us 4. to respond to your questions and provide related membership or customer services 5. to improve the STC Websites 6. to send you STC publications, information about member benefits and special offers, and other information that STC believes is relevant and useful to its members, where you have not opted out of receiving such information 7. to send you third party information that STC believes is relevant and useful to you, where you have given your consent 8. to notify you about changes to your membership or related services or to ask you to provide feedback 9. to enable you to partake in a prize draw, competition or complete a survey 10. to administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 11. to comply with all applicable laws or legal processes, including providing information on individual users to the appropriate governmental authorities where required by law enforcement or judicial authorities 12. in matters involving a danger to personal or public safety, or to protect the rights, property or safety of STC, our members, customers, certificants or others STC may voluntarily provide information to appropriate governmental authorities 13. in some cases members may receive products or services, which are paid for by their government employer, and as a result of payment by the government employer, the record must be open for public access pursuant to applicable law, such as the Florida Public Records Act, and STC will share such information pursuant to those laws
b) Site Use Information
As mentioned above, STC uses the aggregate, anonymous data collected to let our sponsors/advertisers know the number of impressions or views and the number of “click throughs” on their advertisement(s). STC also uses this aggregate, anonymous data to perform statistical analyses of the collective characteristics and behavior of visitors to STC Websites; to measure user interests regarding specific areas of STC Websites; and to analyze how and where best to use our resources. Without such data, we would not know which parts of STC Websites are the most popular, and we would not be able to change and update the content and services appropriately.
c) Information Collected in Connection with Certification and Recertification
If you register for certification or recertification services, or for any other STC credential or certificate (e.g. Certified Corporate Wellness Specialist®), STC uses any personal information you may provide doing so in the same manner as we do when you register for other STC products and services. Without limitation of the foregoing, STC (and/or STC’s certification or credential-related vendors) may use and disclose personal information, certification exam performance information, and/or assessment information related to any other STC credential or certificate in connection with (the following is a non-exclusive list of examples):
- Listing all individuals who have achieved a STC certification in the STC Online Certified Directory
- Sending notifications/reminders on the status of certification or other credential or certificate, information on professional development and recertification opportunities, and other news and communications of interest to the certified community or those holding any other STC credential or certificate
- The scheduling and administration of exams
- The preparation, review, updating, validation, accreditation and/or administration of the exams and exam preparation materials
- Publishing information regarding a candidate/certificant/credential-holder/certificate-holder against whom disciplinary action has been taken and the reason for that action. Examples of how STC will not share a candidate’s/certificant’s/credential-holder/certificate-holder’s personal information, certification exam performance information, or assessment information related to any other STC credential or certificate are as follows:
- STC will not share the names of candidates who do not pass the exam with the general public.
- STC will not share information about an examinee’s performance on individual exam items with any person or entity.
- STC will not disclose any personal information related to requests for reasonable accommodation under the ADA, or under similar Non-US requirements, other than as reasonably necessary to review and/or provide that accommodation.
However, STC may disclose the above information as reasonably necessary in relation to the administration of the exam and exam program (e.g. to communicate ADA accommodations to our exam testing centers as necessary); to comply with the law, regulation, pursuant to court order or other legal process; in connection with the preparation, review, updating, validation, accreditation and/or administration of the exam or exam preparation materials; or to protect the rights, property or safety of STC, our members, certificants or others.
5. How can you review and modify your personal information?
You have the following options for modifying or causing to be deleted personal information or demographic information previously provided by you to STC. 1. E-mail: email@example.com 2. Send mail to the following postal address: Say Travel Consulting Inc. 80 Cosburn Avenue unit 803 Toronto, On. Canada M4K 2G6: Customer Care Department. 3. Call: +1-416-464-7151.
6. What is the opt-out policy for STC Websites?
STC provides members and customers with the opportunity to opt-out of receiving communications from us and our partners. If you no longer wish to receive specific communications or services, you have the following options: 1. You can send an e-mail to: firstname.lastname@example.org 2. You can send mail to the following postal address: Say Travel Consulting Inc. 80 Cosburn Avenue unit 803 Toronto, On. Canada M4K 2G6: Customer Care Department. 3. You can call the following telephone number: +1-416-464-7151. Instructions for opting out of any STC e-mail newsletter you receive are included with each email.
7. Your California Privacy Rights
For California Residents Only. STC may disclose your personal information to our subsidiaries or other third parties who may use that information to market directly to you. As a California resident, you have the right to opt-out of having your personal information licensed to such third parties. We will not share your information after we have received your notification that you are opting out. If you wish to opt-out you have the following options: 1. You can send an e-mail email@example.com 2. You can send mail to the following postal address: Say Travel Consulting Inc. 80 Cosburn Avenue unit 803 Toronto, On. Canada M4K 2G6 Customer Care Department. 3. You can call the following telephone number: +1-416-464-7151.
8. Your European Privacy Rights
For European Residents Only. If you are based in the EU, in certain circumstances, you have rights under the GDPR in relation to your personal information.
If you wish to exercise your European data subject rights, you have the following options: 1. You can send an e-mail to: firstname.lastname@example.org 2. You can send mail to the following postal address: Say Travel Consulting Inc. 80 Cosburn Avenue unit 803 Toronto, On. Canada M4K 2G6: Customer Care Department. 3. You can call the following telephone number: +1-416-464-7151.
9. What kinds of security procedures are in place to protect against the loss, misuse or alteration of your information?
STC Websites have security measures equal to or better than those reasonably expected in the industry, such as firewalls, in place to protect against the loss, misuse and alteration of your personal information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we take reasonable precautions to prevent such unfortunate occurrences. Certain particularly sensitive information, such as your credit card number, collected for a commercial transaction is encrypted prior to transmission. You are ultimately responsible for the security of your STC or affiliate login credentials. You may not share your STC or affiliate login credentials with colleagues or friends so they can access content or features that are restricted to STC or association members only. You should log out of your browser at the end of each computer session to ensure that others cannot access your personal information and correspondence, especially if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe.
10. How do STC Websites use bulletin boards, discussion lists, and moderated chats?
STC Websites make bulletin boards, discussion lists, and moderated chats available to its members. Any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your personal information. Although users may post messages that will appear on the message boards anonymously, STC does retain a record of who posts all notes.
If you submit personal information to STC through any channel other than STC Websites, the same privacy rules set forth at Part I above for STC Websites will be applied to such personal information you submit through channels other than STC Websites (including without limitation your opt-out rights at Part I, Section 6 above), except as follows:
- The “cookies” and other tracking devices used by STC Websites and described in Part I above do not apply to personal information gathered through channels other than STC Websites.
- Hardcopy personal information provided to STC which is not converted to electronic media and hosted by STC will be subject to different security procedures than will stored electronic personal information. STC has security measures equal to or better than those reasonably expected in the industry, in place to protect against the loss, misuse and alteration of your hardcopy personal information under our control.