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   TRAKSTAR'S PLATFORM
   
   See how Trakstar's software can streamline your business.
   
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   PERFORMANCE MANAGEMENT
   
   Align goals, lay pathways, and show your employees what "good" looks like.
   
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   LEARNING MANAGEMENT
   
   Build better education programs and learning paths for onboarding and
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   APPLICANT TRACKING
   
   Streamline hiring process with job postings, collaborative hiring, and
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   WORKFORCE ANALYTICS
   
   Use critical workforce data to shape great business outcomes and measure
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   See how Trakstar's platform works with your existing HR software to make your
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   PLATFORM
   
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   SOLUTIONS
   
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IMPORTANT POLICIES

 * Privacy Policy
 * Terms & Conditions
 * California Consumer Privacy Act
 * UK & EU Privacy Rights
 * Data Processing Addendum
 * Acceptable Use Policy
 * Vulnerability Disclosure Policy
 * Cigna Machine-Readable Files Policy


PRIVACY

Last updated as of the 22nd day of June, 2022




INTRODUCTION

Applied Training Systems, Inc., doing business as Trakstar ("Trakstar,"
"Company," "we" or "our") respect your privacy and are committed to protecting
it through our compliance with this policy.

This policy describes the types of information we may collect from you or that
you may provide when you visit the website and application located at
https://trakstar.com (collectively, our "Application") and our practices for
collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

 * On this Application.
 * In email, text, and other electronic messages between you and this
   Application.
 * From integrated third-party sources such as human resource information
   systems.
 * When you permit us to record meetings between ourselves and you.

It does not apply to information collected by:

 * Us offline or through any other means, including on any other website
   operated by Company or any third party (including our affiliates and
   subsidiaries); or
 * Any third party (including our affiliates and subsidiaries), including
   through any application or content that may link to or be accessible from or
   on the Application

Please read this policy carefully to understand our policies and practices
regarding your information and how we will treat it. If you do not agree with
our policies and practices, your choice is not to use our Application. By
accessing or using this Application, you agree to this privacy policy. This
policy may change from time to time (see Changes to Our Privacy Policy). Your
continued use of this Application after we make changes is deemed to be
acceptance of those changes, so please check the policy periodically for
updates.


CHILDREN UNDER THE AGE OF 16

Our Application is not intended for children under 16 years of age. No one under
age 16 may provide any information to the Application. We do not knowingly
collect personal information from children under 16. If you are under 16, then
do not use or provide any information on this Application, including without
limitation registering on the Application, making any purchases through the
Application, using any of the interactive features of this Application, or
providing any information about yourself to us, such as your name, address,
telephone number, email address, or any user name you may use. If we learn we
have collected or received personal information from a child under 16 without
verification of parental consent, then we will delete that information. If you
believe we might have any information from or about a child under 16, then
please contact us at support@trakstar.com.


INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Accounts are provisioned under a subscription agreement (such agreement,
together with all order forms and addenda attached thereto, the "Subscription
Agreement") that Trakstar has established with the entity providing your
employment, job application portal, or training services (the "Customer").
Information provided by you is available and accessible by the Customer to whom
your account is provisioned. Your use of the Application is conditioned on the
Subscription Agreement, and you may lose access to the Application at any time
should the Subscription Agreement terminate. Further, you understand that the
Customer may access any information that Trakstar collects from or about you
through the Application.

We collect several types of information from and about users of our Application,
including information:

 * By which you may be personally identified, such as name, postal address,
   e-mail address, telephone number, resumes, employee notes, performance
   reviews, goal attainment and progress, 360 reviews, training records and any
   other identifier by which you may be contacted online or offline ("personal
   information");
 * That is about you but individually does not identify you, such as job
   descriptions, succession planning information, and demographic data; and/or
 * About your internet connection, the equipment you use to access our
   Application, and usage details.

We collect this information:

 * Directly from you when you provide it to us.
 * Automatically as you navigate through the site. Information collected
   automatically may include usage details, IP addresses, and information
   collected through cookies, web beacons, and other tracking technologies.
 * From third parties, for example, your employer.

Information You Provide to Us

The information we collect on or through our Application may include:

 * Information that you provide by filling in forms on our Application. This
   includes information provided at the time of registering to use our
   Application, subscribing to our service, posting material, or requesting
   further services. We may also ask you for information when you report a
   problem with our Application.
 * Records and copies of your correspondence (including email addresses), if you
   contact us.
 * Your responses to surveys that we might ask you to complete for research
   purposes.
 * Details of transactions you carry out through our Application and of the
   fulfillment of your orders. You may be required to provide financial
   information before placing an order through our Application.
 * Your search queries on the Application.
 * Information provided about you by third-party systems integrated to the
   Application.
 * Your demographic data, goal attainment and progress reports, 360 reviews,
   engagement surveys and results, training records, quiz assessment results,
   resumes, contact information, and feedback.

You also may provide information to be transmitted to other users of the
Application (collectively, "User Contributions"). Your User Contributions are
transmitted to others at your own risk. Although we limit access to certain
pages, please be aware that no security measures are perfect or impenetrable.
Therefore, we cannot and do not guarantee that your User Contributions will not
be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Application, we may use automatic
data collection technologies to collect certain information about your
equipment, browsing actions, and patterns, including:

 * Details of your visits to our Application, including traffic data, location
   data, logs, and other communication data and the resources that you access
   and use on the Application.
 * Information about your computer and internet connection, including your IP
   address, operating system, and browser type.

We also may use these technologies to collect information about your online
activities over time and across third-party websites or other online services
(behavioral tracking).

The information we collect automatically is only statistical data and does not
include personal information, but we may maintain it or associate it with
personal information we collect in other ways. It helps us to improve our
Application and to deliver a better and more personalized service, including by
enabling us to:

 * Estimate our audience size and usage patterns.
 * Recognize you when you return to our Application.

The technologies we use for this automatic data collection may include:

 * Cookies (or browser cookies). A cookie is a small file placed on the hard
   drive of your computer. You may refuse to accept browser cookies by
   activating the appropriate setting on your browser. However, if you select
   this setting, you may be unable to access certain parts of our Application.
   Unless you have adjusted your browser setting so that it will refuse cookies,
   our system will issue cookies when you direct your browser to our
   Application.
 * Web Beacons. Pages of our Application and our e-mails may contain small
   electronic files known as web beacons (also referred to as clear gifs, pixel
   tags, and single-pixel gifs) that permit the Company, for example, to count
   users who have visited those pages or opened an email and for other related
   website statistics (for example, recording the popularity of certain website
   content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this
information to personal information about you that we collect from other
sources, or you provide to us.


THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications on the Application are served by third-parties,
including but not limited to, analytics, user engagement, CRM, and other
application providers. These third parties may use cookies alone or in
conjunction with web beacons or other tracking technologies to collect
information about you when you use our website. The information they collect may
be associated with your personal information or they may collect information,
including personal information, about your online activities over time and
across different websites and other online services. They may use this
information to provide you with interest-based (behavioral) advertising or other
targeted content.

We do not control these third parties' tracking technologies or how they may be
used. If you have any questions about an advertisement or other targeted
content, you should contact the responsible provider directly. For information
about how you can opt out of receiving targeted advertising from many providers,
see Choices About How We Use and Disclose Your Information.


HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us,
including any personal information:

 * To present our Application and its contents to you.
 * To provide you with information, products, or services that you request from
   us.
 * To fulfill any other purpose for which you provide it.
 * To provide you with notices about your account or subscription, including
   expiration and renewal notices.
 * To carry out our obligations and enforce our rights arising from any
   contracts entered into between you or the entity providing your employment,
   job application portal, or training services and us, including for billing
   and collection.
 * To notify you about changes to our Application or any products or services we
   offer or provide through it.
 * To allow you to participate in interactive features on our Application.
 * To create benchmark reports from de-identified, anonymized usage data
 * In any other way we may describe when you provide the information.
 * For any other purpose with your consent.

We may also use your information to contact you about our goods and services
that may be of interest to you. If you do not want us to use your information in
this way, please use the unsubscribe option included in the email. For more
information, see Choices About How We Use and Disclose Your Information.


DISCLOSURE OF YOUR INFORMATION

Where the applicable Subscription Agreement permits, we may disclose aggregated
information about our users, and information that does not identify any
individual, without restriction.

We may disclose personal information that we collect, or you provide as
described in this privacy policy:

 * To our subsidiaries and affiliates.
 * To contractors, service providers, and other third parties we use to support
   our business and who are bound by contractual obligations to keep personal
   information confidential and use it only for the purposes for which we
   disclose it to them, including service providers located in the United States
   or elsewhere in the world for the purposes described in this privacy policy.
   These providers are detailed in the Sub-processors list within the Trakstar
   Data Processing Addendum. Different countries have different privacy laws and
   requirements, and some, including the United States, provide less legal
   protection for your personal information than others. Please know, however,
   that no matter where your personal information is collected, used,
   transferred, or stored, if it was collected through our websites, it will be
   governed by and used in accordance with the terms of this privacy policy and,
   where applicable, our Data Processing Addendum.
 * To a buyer or other successor in the event of a merger, divestiture,
   restructuring, reorganization, dissolution, or other sale or transfer of some
   or all of Trakstar's assets, whether as a going concern or as part of
   bankruptcy, liquidation, or similar proceeding, in which personal information
   held by Trakstar about our Application users is among the assets transferred.
 * To fulfill the purpose for which you provide it. For example, if you give us
   an email address to submit your candidacy for a job posting feature of our
   Application, we will transmit your email address to the employer who posted
   that job opening.
 * For any other purpose disclosed by us when you provide the information.
 * With your consent.

We may also disclose your personal information:

 * To comply with any court order, law, or legal process, including without
   limitation as set forth in our Data Processing Agreement and/or to respond to
   any government or regulatory request.
 * To enforce or apply our terms of use, found at
   https://www.trakstar.com/terms/, and other agreements, including for billing
   and collection purposes.
 * If we believe disclosure is necessary or appropriate to protect the rights,
   property, or safety of Trakstar, our customers, or others.


CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you
provide to us. We have created mechanisms to provide you with the following
control over your information:

 * Tracking Technologies and Advertising. You can set your browser to refuse all
   or some browser cookies, or to alert you when cookies are being sent. If you
   disable or refuse cookies, please note that some parts of this site and
   application will then be inaccessible or not function properly.
 * Promotional Offers from the Company. If you do not wish to have your email
   address/contact information used by the Company to promote our own or third
   parties' products or services, you can opt-out by checking the relevant box
   located on the form on which we collect your data (the order
   form/registration form)/OTHER OPT-OUT METHOD or at any other time by logging
   into the Application and adjusting your user preferences in your account
   profile by checking or unchecking the relevant boxes or by sending us an
   email stating your request to support@trakstar.com. If we have sent you a
   promotional email, you may send us a return email asking to be omitted from
   future email distributions. This opt out does not apply to information
   provided to the Company as a result of a product purchase, warranty
   registration, product service experience or other transactions.

California residents may have additional personal information rights and
choices. Please see Your California Privacy Rights (below) for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada
Revised Statutes Chapter 603A may submit a request to this designated address:
support@trakstar.com. However, please know we do not currently sell data
triggering that statute's opt-out requirements.

UK and EU residents may have additional personal information rights and choices.
Please see UK and EU Residents’ Rights (below) for more information.


ACCESSING AND CORRECTING YOUR INFORMATION

You can review and change your personal information by logging into the
Application and visiting your account profile page.

You may also send us an email at support@trakstar.com to request access to,
correct or delete any personal information that you have provided to us. We
cannot delete your personal information except by also deleting your user
account, and we only delete user accounts in response to Customer’s request. We
may not accommodate a request to change information if we believe the change
would violate any law or legal requirement or cause the information to be
incorrect.

If User Contributions are deleted from the Application, copies of your User
Contributions may remain viewable in cached and archived pages or might have
been copied or stored by other Application users. Proper access and use of
information provided on the Application, including User Contributions, is
governed by our terms of use found at https://trakstar.com/terms/. California
residents may have additional personal information rights and choices. Please
see Your California Privacy Rights (below) for more information.

UK and EU residents may have additional personal information rights and choices.
Please see UK and EU Residents’ Rights (below) for more information.


YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional
rights regarding our use of your personal information. To learn more about your
California privacy rights, visit https://trakstar.com/ccpa/.

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users
of our Application that are California residents to request certain information
regarding our disclosure of personal information to third parties for their
direct marketing purposes. To make such a request, please send an email to
support@trakstar.com.


UK AND EU RESIDENTS' RIGHTS

If you are an EU or UK resident, you may have certain additional privacy rights.
To learn more about your rights, please visit our UK & EU Privacy Rights page
for more information.

Even though we do not rely on the EU-U.S. Privacy Shield Framework as set forth
by the U.S. Department of Commerce regarding the collection, use, and retention
of personal information transferred from the European Union to the United States
(the "Privacy Shield"), we do continue to comply with the commitments set forth
below that we made when we certified to the Privacy Shield principles ("Privacy
Shield Principles"). Trakstar has certified to the Department of Commerce that
it adheres to the Privacy Shield Principles. To learn more about the Privacy
Shield program, and to view the Trakstar certification, please visit
https://www.privacyshield.gov/

Further, Trakstar will execute a Data Processing Addendum with customers to whom
this legislation applies. For clarity, Trakstar clients are the data controllers
and Trakstar is a data processor, as such terms are defined by the GDPR. Note
that where there is a conflict between the terms in this privacy policy, the
Privacy Shield Principles, and the GDPR legislation, the GDPR legislation shall
govern.

In compliance with the Privacy Shield Principles, Trakstar commits to resolve
complaints about Trakstar’s collection or use of your personal information. EU
individuals with inquiries or complaints regarding the Trakstar Privacy Shield
policy, the Trakstar Data Processing Addendum, or Trakstar compliance with GDPR
should first contact ATSI at the support email address included within this
policy.

Trakstar has further committed to cooperate with EU data protection authorities
(DPAs) and comply with the advice given by such authorities with regards to
unresolved Privacy Shield complaints concerning human resources data transferred
from the EU in the context of the employment relationship. If timely
acknowledgment of your complaint is not received from Trakstar, or if Trakstar
has not addressed your complaint to your satisfaction, please contact the EU
DPAs for more information or to file a complaint. The services of EU DPAs are
provided at no cost to you.

Trakstar commits to cooperate with EU DPA’s and comply with the advice given by
EU DPAs with regards to human resources data transferred to Trakstar in the
context of the employment relationship.

We sometimes provide personal information to third parties to perform services
on our behalf. If we transfer personal information received under the Privacy
Shield to a third party, the third party's access, use, and disclosure of the
personal information must also be in compliance with our Privacy Shield
obligations, and we will remain liable under the Privacy Shield for any failure
to do so by the third party unless we prove we are not responsible for the event
giving rise to the damage.


DATA SECURITY

We have implemented measures designed to secure your personal information from
accidental loss and from unauthorized access, use, alteration, and disclosure.
All information you provide to us is stored on our secure servers behind
firewalls. Any payment transactions and other information will be encrypted
using SSL technology.

The safety and security of your information also depends on you. Where we have
given you (or where you have chosen) a password for access to certain parts of
our Application, you are responsible for keeping this password confidential. We
ask you not to share your password with anyone. We urge you to be careful about
giving out information in public areas of the Application like message boards.
The information you share in public areas may be viewed by any user of the
Application.

Unfortunately, the transmission of information via the internet is not
completely secure. Although we do our best to protect your personal information,
we cannot guarantee the security of your personal information transmitted to our
Application. Any transmission of personal information is at your own risk. We
are not responsible for circumvention of any privacy settings or security
measures contained on the Application.


THIRD-PARTY PRODUCTS AND SERVICES

You or the Trakstar Customer have the ability to connect third-party products
and services (such as Google) to the Trakstar applications. When you use
third-party products and services, their terms and privacy policies apply to
your use of those products or services. This privacy policy does not apply to
information collected by such third parties, and Trakstar encourages you to
learn more about their privacy practices before using their products or
services.


ADDITIONAL LIMITS ON USE OF YOUR GOOGLE USER DATA

Notwithstanding anything else in this privacy policy, if you deliberately and
voluntarily provide the Trakstar applications access to your Google data through
an optional integration, then Trakstar’s use of that data will be subject to
these additional restrictions:

 * Trakstar’s use and transfer to any other app of information received from
   Google APIs will adhere to Google API Services User Data Policy, including
   the Limited Use requirements.
 * Trakstar will only use access to read, or control Gmail message bodies
   (including attachments), metadata, headers, and settings to provide an email
   client on your device that allows users to compose, send, read, and process
   emails which are marked with a specific label. Trakstar will never delete any
   email from your mailbox.
 * Trakstar will not transfer this Gmail data to others unless doing so is
   necessary to provide and improve these features, comply with applicable law,
   or as part of a merger, acquisition, or sale of assets.
 * Trakstar will not use this Gmail data for serving advertisements.
 * Trakstar will not allow humans to read this data unless Trakstar has your
   consent for specific conversations, doing so is necessary for security
   purposes such as investigating abuse, to comply with applicable law, or for
   the application’s internal operations and even then, only when the data have
   been aggregated and anonymized.

Trakstar’s Obligations

 * Trakstar will only process client information or your information for the
   contracted business purposes for which Client provides or permits access to
   personal information.
 * Trakstar will not process or sell client personal information for Trakstar’s
   own commercial purposes or in a way that does not comply with applicable data
   protection law. If a law requires Trakstar to disclose Client or your
   personal information for a purpose unrelated to the contracted business
   purpose, Trakstar must first inform the Client of the legal requirement and
   give the Client an opportunity to object or challenge the requirement, unless
   the law prohibits such notice.
 * Trakstar will limit its processing of client personal information or your
   information to activities reasonably necessary and proportionate to achieve
   the contract business purposes. Once the contracted business purposes are
   achieved or the agreement is terminated, Trakstar will return or destroy all
   Client or your personal information upon request of the Client unless
   Trakstar is required by a specific legal obligation to retain Client or your
   Personal Information. If Trakstar must retain Client or your personal
   information, it shall only do so for as long as is strictly necessary to
   fulfill such legal obligation, after which it will destroy Client or your
   personal information upon request of the Client.
 * Trakstar must promptly comply with any Client request or instruction from
   authorized persons requiring Trakstar to provide, amend, transfer, or delete
   Client or your Personal Information, or to stop, mitigate, or remedy any
   processing that may violate any applicable Data Protection Law.
 * If the contracted business purpose requires the collection of personal
   information from you or individuals on Client’s behalf, Trakstar will always
   provide appropriate notice such as this CCP compliant notice for your review.
 * Trakstar will implement and maintain industry standard practices, using
   technical and organizational security measures customarily adhered to within
   the industry, to ensure the security, confidentiality and integrity of all
   Client and your data and other information or materials transmitted to or
   stored on the System by or on behalf of Client or any user. Upon reasonable
   suspicion or confirmation that a Personal Data Breach has occurred, Trakstar
   will notify affected parties as soon as practicable.
 * Trakstar may collect anonymized Service information, such as usage or traffic
   patterns, and aggregate it with such data from other Clients and Users to
   generate statistical information to analyze and improve the Services.
   Trakstar will take reasonable measures to ensure this information cannot be
   associated with Client, Client’s Users or any identifiable natural person.
   Trakstar commits to only using such anonymized and aggregate Service
   Information in deidentified form and will not attempt to reidentify the
   information. Trakstar contractually obligates any recipients of anonymized or
   aggregate Service information to abide by the same restriction with respect
   to such information.


CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page.
If we make material changes to how we treat our users' personal information,
then we will use commercially reasonable efforts to notify you by email to the
primary email address specified in your account and/or through a notice on the
Application home page. The date the privacy policy was last revised is
identified at the top of the page. You are responsible for ensuring we have an
up-to-date active and deliverable email address for you, and for periodically
visiting our Application and this privacy policy to check for any changes.


CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices,
or to register a complaint or concern, please contact us at:

trakstar
113 cherry st.
pmb 57615
seattle, wa 98104-2205

support@trakstar.com

1 (877) 489-5651

 

Chris McClave, Data Protection Officer, CTO

Learn more about Trakstar



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SOLUTIONS

 * Performance Reviews
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 * 360-Degree Reviews
 * Training Course Creation
 * Candidate Sourcing
 * Benchmarking


RESOURCES

 * How to Write SMART Goals
 * Employee Feedback Best Practices
 * Comparison
 * Blog
 * Whitepapers
 * Webinars
 * Podcasts
 * Academy
 * Perform Status
 * Hire Status
 * Learn Status


COMPANY

 * Customers
 * About
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 * Security
 * Terms and Conditions
 * Privacy Policy
 * Vulnerability Disclosure Policy

© 2001-2022 Trakstar. All rights reserved.


MID-YEAR REVIEWS ARE ALMOST HERE!

Are you ready for your Mid-Year Reviews? Trakstar Perform has you covered! Click
below for our best tips to prepare for mid-year reviews, for all your users,
including:

 * Pro Tips for Admins
 * Week-by-Week Actionable Timeline
 * Guides for Managers & Employers

Learn More About Mid-Year Reviews →


HAVING AN EMPLOYEE REVIEW CAN BE DIFFICULT FOR MANAGERS.

You have to fit a lot into a short amount of time. With our interactive
performance review checklist, you'll be able to get it done a lot faster.
Including:

 * Tips for prep work to make the review easier
 * Steps for before, during, and after the review

Download our Free Manager Review Checklist →


TRYING TO SET LEARNING GOALS FOR YOUR WORKFORCE?
TRAKSTAR LEARN HELPS YOU GET THERE!

Use our SMART goal setting worksheet to help you plan for your future success.

 * Step-by-Step Goal Setting
 * Planning for Roadblocks
 * Identifying Motivators

Download SMART Goal Setting Worksheet →


ONBOARDING YOUR EMPLOYEES IN THE RIGHT WAY HELPS YOU SET THEM UP FOR SUCCESS.

Do you need to overhaul your onboarding process? Our free onboarding checklist
is here to help!

 * Set Expectations
 * Establish Relationships
 * Create a Repeatable Program

Download Free Onboarding Checklist →


WANT TO GO ABOVE AND BEYOND SIMPLE EMPLOYEE DATA AND UNDERSTAND HOW HR
INITIATIVES IMPACT YOUR WORKFORCE?

Insights can help you do that. Watch our Uncover The Hidden Value of Your People
Data webinar replay to learn more, including:

 * How can HR get a seat at the table?
 * What is People Data?
 * How can you use data to make real-life decisions?

Watch our On-Demand Webinar now →








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