(Effective March 21, 2019)
Find out what data we collect and how we use it.
Welcome to the Baton Simulations website located at https://batonsimulations.com (the “Website”) which includes all subdomains present and future (including but not limited to the instructor portal), and the Baton Simulations’ products and services such as ERPsim and DAS (Digital Acceleration Solution) (collectively the “Services”). We hope you enjoy your visit and / or use of the Website and Services.
Key Elements of this Policy
Here are the key elements of this Policy so you can know the important parts right away to make an informed decision about your consent for our collection and use of your personal data. You can find the details in the rest of the Policy.
|Personal data we collect from you||What we do with it||Third parties we share it with|
|Contact information||Communicate with you and manage our relationship, depending on your relationship with us||Companies that provide our CRM services, such as Oracle|
|Account information||Manage your account and enable logging in to the Website or Services||Companies that provided the infrastructure for the Website and Services, such as Media Temple|
Before we get started with the details, here are a few terms we think you should know as you read this Policy.
“Data Protection Laws” refers to the laws that are designed to protect your personal data and privacy, depending on the place where you live. This includes the “GDPR”, the European data protection law which stands for “General Data Protection Regulation”, with the official name Regulation (EU) 2016/679 of the European Parliament and of the Council, and which covers our European visitors and users. It also includes “PIPEDA” (Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our activities in Canada, as Baton Simulations is a Canadian company.
“Personal data” – this is information we collect from you or about you and which is defined in the GDPR as “any information relating to an identified or identifiable natural person.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you. Under PIPEDA, the equivalent concept is “personal information”, which is roughly the same. Any mention of “personal data” in this Policy shall also mean personal information.
About Us and Contacting Us
Baton Simulations Inc. (“Baton Simulations”) is a duly-incorporated company in the Province of Quebec, Canada. Where this Policy refers to “Baton Simulations”, it may refer to Baton Simulations Inc. and / or its shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns, depending on the context.
Under the GDPR, Baton Simulations is a “data controller”. That means we collect personal data directly from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means collection, use, storage, transfer or any other action related to your personal data; it is used in this Policy in that way.
If you want to ask us anything about what’s in this Policy, or anything else privacy- or data- related, you can email:
Baton Simulations Privacy Officer
Here is the mailing address for you as well:
Baton Simulations Privacy Officer
54 Le Royer St. West
Canada H2Y 1W7
You have the following rights regarding your personal data held by Baton Simulations, and other rights:
- The right to withdraw at any time your consent for Baton Simulations to process your personal data;
- The right to have your personal data erased from Baton Simulations’ records;
- The right to access your personal data and any relevant information around its processing and use;
- The right to have a copy of your personal data given to you in an easy to read format so that you can transfer it to another data processor;
- The right to have your personal data corrected if you believe it is inaccurate;
- The right to restrict the processing of your personal data if it is inaccurate or if our processing or use of it is against the law; and
- The right to refuse any marketing targeted at you by Baton Simulations.
If you wish to exercise any of these rights, please contact our Privacy Officer at the contact information above. Please note that if you ask for your personal data to be deleted, you may not be able to use certain of the Services, depending on a number of factors.
Personal Data Collected from You and What We Use It For
In the table below, please find the personal data we may collect from you directly, what we use it for, and the legal basis under the GDPR for us having and processing this personal data. Under PIPEDA, the legal basis is your informed consent, and by submitting this personal data you acknowledge having granted this consent to Baton Simulations.
|Personal data category||Personal data collected / processed||What we use it for (the “purpose” of processing)||Legal basis for processing under the GDPR|
|Website visitor contact information||Your name and email address, and optionally your phone number||To communicate with you if you use a Website contact form||Your consent in giving us this information|
|Client contact information||Your name, email address, and mailing address||To communicate with you and manage the client relationship||Performance of a contract between you and us|
|Supplier contact information||Your name, email address, mailing address, and phone number||To communicate with you and manage the supplier relationship||Performance of a contract between you and us|
|Sales leads contact information||Your name, email address, mailing address, and phone number||To communicate with you about the Services||Your consent in giving us this information|
|Testimonial information||Your name and any other Personal Information you may include in your testimonial||To post your testimonial on our Website||Your consent in giving us this information|
|DAS user account information||Your name, username, email address, and phone number||To create a DAS account for you, manage the account, and communicate with you||Performance of a contract between you (or your employer) and us, or your consent in giving us this information|
|Instructor account information||Your name, username, email address, mailing address, and phone number||To create an instructor account for you, manage the account, and communicate with you||Performance of a contract between you and us|
|Financial information for suppliers and instructors||Your payment information such as bank account details||To pay you, if you are a supplier or an instructor for the Services||Performance of a contract between you and us|
Where you have provided personal data further to the contract between you and us, or if you fail to provide such data or withdraw your consent to use such data, we may no longer be able to provide you with the Services, depending on the nature of the request.
Personal Data Collected About You from Third Parties
We do not currently collect any personal data about you from third parties.
Sensitive Personal Data
We do not collect any of what the GDPR considers sensitive personal data from you.
Who We Transfer Your Personal Data To
We routinely share some of your personal data with certain third parties who are identified in the table below along with what they do with it. All of the third parties are bound by contractual relationships with us not to do anything with your personal data except what is identified in the table.
Some of those third-party recipients may be based outside your home jurisdiction. If you are in the European Economic Area, please see the “Transfer of Your Personal Data Outside of the European Economic Area” further down in this Policy for more information including on how we safeguard your personal data when this occurs.
We will share personal data with law enforcement or other authorities if: (1) we are required by applicable law, to meet national security or law enforcement requirements; (2) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of any contract between you and Baton Simulations; or (3) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Website or Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks or similar).
We will never share your personal data with third parties except under these circumstances.
|Personal data category||Who we transfer it to||What they do with it|
|All categories of contact information||Oracle NetSuite||Store it so that we can retrieve it and communicate with you; integrate it with their software that facilitates relationship management|
|DAS user account information||Companies that provided the infrastructure for the Services (DAS only), specifically SAP||Store it so that you can log into your DAS account|
|Instructor account information||Companies that provided the infrastructure for the Website, specifically Media Temple||Store it so that you can log into your instructor account|
|Financial information for suppliers and instructors||Positive Venture Group and Oracle||Store it and use it to make payments to you|
|Analytics identifiers||Companies that provide data analytics, specifically Google Analytics||Provide us with analytics as to how the Website is used, and to trace fraudulent activities|
|Advertising identifiers||Bloom online marketing, and advertising companies specifically Google and LinkedIn||Run online advertising campaigns for us, as described more fully further in this Policy|
Tracking Technology (“Cookies” and Related Technologies)
Baton Simulations uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) on the Website and in the Services and by visiting or using the Website or Services you agree to their use. Cookies are small text files placed on your computer or device when you visit a website, in order to track use of the site and to improve the user experience by storing certain data on your computer or device.
- to facilitate your signing-in to the Services, specifically DAS;
- to keep track of translated text when you use DAS;
- to provide general internal and user analytics and to conduct research to improve the content of the Website using analytics program as described above in this Policy;
- to facilitate online advertising, as described more fully in the next section of this Policy; and
- to assist in identifying possible fraudulent activities.
Baton Simulations Advertising and Opting Out
Baton Simulations currently uses Google AdWords and Display Network and by using our Services you consent to this use. Specifically, Baton Simulations uses the remarketing features of interest-based advertising of Google AdWords that delivers you advertisements that will be of particular interest to you, based on your browsing and activity history at our Website and Services. These advertisements will appear on third-party websites around the web. Google uses specific cookies to allow them to serve these ads around the web.
You may prevent this type of advertising by deleting the appropriate Google cookie through your browser, though this may not be permanent. For a more permanent solution, you may opt out of such Google advertising by adjusting your Google ad settings or using the WebChoices online opt-out tool.
How We Protect Your Personal Data
We have implemented very strict technical and organisational procedures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed by us. These procedures prevent your personal data from being lost; or used or accessed in any unauthorised way.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws requires us to do so, and within the time frame required by the applicable Data Protection Law.
Baton Simulations uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal data) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Website and Services, and these third parties have been selected for their high standards of security, both electronic and physical. These third parties are limited to Media Temple, Amazon AWS, and SAP.
Finally, all information, including personal data, is transferred with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for Internet data transfer and transactions. You can use your browser to check Baton Simulations’ valid SSL security certificate.
Transfer of Your Personal Data Outside of the European Economic Area (EEA)
For our European users, we endeavour to keep your personal data inside the EEA. However, Baton Simulations and certain of our third-party providers are in countries outside the EEA where your personal data may be transferred. These countries, however, are limited to countries with particular circumstances that protect your data, specifically:
- Canada. Canada has been determined to have an “adequate level of protection” for your personal data under European data protection law.
- The United States. Your personal data is only transferred to companies in the United States that: (1) participate in the Privacy Shield; and (2) have signed agreements with us or have informed us that they are GDPR-compliant.
That’s it! You have the right, however, to refuse to have your data transferred outside the EEA. Please contact our Privacy Officer to make that request.
Supervisory Authorities and Complaints
If you are in the EEA, under the GDPR you have the right to make a complaint to the appropriate supervisory authority. If you are not satisfied with the response received or the actions taken by our Privacy Officer, or if you would like to make a complaint directly about Baton Simulations’ data practises, we invite you to contact the supervisory authority in your country. If you are in the U.K. for example, you should contact the Information Commissioner’s Office who is the supervisory authority. You can reach them in a variety of ways, including by phone (0303 123 1113 in the UK) and mail (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF).
The full listing of all Data Protection Authorities (the supervisory authorities) across the EEA and their contact information can be found here.
If you are in Canada and you are not satisfied with the response received or the actions taken by our Privacy Officer, you can make a complaint to the Office of the Privacy Commissioner of Canada. Instructions on how to do so can be found on their website.
Your personal data will only be kept for as long as it is necessary for the purpose needed for that processing. For example, we will retain your account information for as long as you have an account with us, or your supplier information as long as you are one of our suppliers.
Baton Simulations does not use any automated decision-making processes with your personal data.
Changes to This Privacy Notice
The date at the top of this page indicates when this Policy was last updated. Every now and then, we will have to update this Policy. You can always find the most updated version at this URL, and we will always post a notice on the Website if we make big changes. If you are a user of the Services, we will also email you to tell you the Policy has been updated and what the important changes are, or post a notice when you use the Services for the first time following those changes.