GLOBAL PRIVACY POLICY

1. Introduction

We use your personal information in order to fulfill our commitment to providing an unparalleled client service experience in connection with all of your interactions with Northwest Seminars, Northwest Anesthesia Seminars, and Northwest World-Wide Travel (the “Purpose”). As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.

As one of our clients or someone else with whom we do business, you understand and agree that we collect, use and disclose your personal information in accordance with this Global Privacy Policy (this “Policy”).

2. The Application of this Policy

This Policy applies to personal information regarding clients and other individuals with whom we do business or who attend our seminars and to the use of that personal information in any form, whether oral, electronic or written.

This Policy gives effect to our commitment to protect your personal information and has been adopted by Northwest Seminars, Northwest Anesthesia Seminars, and Northwest World-Wide Travel (“NWWT”). References to “NWS”, “we” and “our” throughout this Policy, depending upon the context, collectively refer to these separate and distinct legal entities.

While this Policy is intended to describe the broadest range of our personal information processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we process that personal information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.

3. Types of Personal Information We Collect

The term “personal information” in this Policy refers to information that does or is capable of identifying you as an individual. The types of personal information that we collect and process (which may vary by jurisdiction based on applicable law) include:

• your name, personal and work contact details, professional title, date of birth, image, and, in some cases, your passport information;

 

• client past, present and future hotel, resort, cruise and tour reservation information, including various hotels, resorts, cruise lines, and tour packages that you have reserved through us, dates of arrival and departure, special requests, made;

 

• your credit card details, your seminar history with us and credentials for the NWS Frequent Attendee Point program;

 

• any information necessary to fulfill special requests (e.g. health conditions that require specific accommodation or services);

 

• information, feedback or content you provide regarding your marketing preferences, in surveys, sweepstakes, contests, or promotional offers, or to our websites;

 

• information collected whilst you access a NWS website (we describe this in more detail in Sections 7 and 8 below);

Much of the personal information we process is information that you or someone acting on your behalf knowingly provides to us. However, in other instances, we process personal information that we are able to infer about you based on other information you provide to us or during our interactions with you, or personal information about you that we receive from a third party. This Policy also applies to the personal information about you that we receive from a third party, unless specifically covered by such third party’s privacy policy.

When you agree to this Policy you are, to the extent required under your local law, granting your express and written consent to the processing of any personal information that you provide to NWS. You are not obliged to provide NWS with any of your Information, however should you choose not to, this will not prevent you from purchasing any products or services from NWS.

4. How We Use Personal Information

Subject to applicable laws, we may collect, use and disclose relevant portions of your personal information in order to:

• provide and charge for hotel, resort, cruise or tour accommodations, seminar tuition fees, and other goods and services;

 

• provide you with a better or more personalized level of service, including information and services from a third party (such as additional client services available at NWS contracted hotels and resorts, cruise lines, tour companies and transportation options);

 

• respond to requests for information and services, including services from a third party (such as cruise lines, tour companies or transportation providers);

 

• administer the NWS Frequent Attendee Point program (FAP)

 

• fulfill contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g. travel agents, group travel organizers, tour companies or your employer) and vendors (e.g. credit card companies, airline operators and third party loyalty programs);

 

• conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions;

 

• administer general record keeping;

 

• meet legal and regulatory requirements;

 

• test and evaluate new products and services; and

 

• NWS uses and retains your personal information for as long as is necessary to fulfill the Purpose and comply with any accreditation body’s requirements.

5. Disclosures of your Personal Information

From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. When you agree to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such other countries for the Purpose and to the extent stated in this section and as described in Section 4 above.
Circumstances where we might make such disclosure (in addition to those described in Section 4 above) include:

5.1 Our Agents, Service Providers and Suppliers

Like most international continuing education providers, we may outsource the processing of certain functions and/or information to third parties. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures.

5.2 Consumer Insights

Where we hold personal information about you, we may disclose this personal information to other companies that also hold information about you. These companies may combine the information in order to better understand your preferences and interests, thereby enabling them and us to better serve you. If your personal information is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under Section 12 below.

5.3 Legal Requirements

We reserve the right to disclose any personal information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting and tax rules and regulations and any specific record retention laws.

6. Centralized Data Processing Activities

Like most international businesses, we have centralized certain aspects of our data processing activities in accordance with applicable laws, which, in many instances, will result in the transfer of your personal information from one country to another. For example, if you make a reservation through NWS for the hotels, resorts, cruise lines or tour providers we have a contract with outside of the United States, the personal information gathered in that process will be transferred to and processed in the United States or the host country, in accordance with NWS’s binding contract with those entities. The jurisdictions where that information will be processed may or may not have laws that seek to preserve the privacy of personal information.

 

7. Information We Collect When You Visit Us Online

If you access any NWS website, you may wish to know the following:

7.1 You Can Browse Without Revealing Who You Are

You can always visit our websites without logging in or otherwise revealing who you are.

 

7.2 Usage Information

When you visit our websites, we collect information about how you use those websites. Examples of such information include the Internet Protocol address automatically assigned to your computer each time you browse the Internet, the date and time of your visit, the pages you access and the amount of time you spend on each page, the type of Internet browser you use, your device’s operating system and the URL of any websites that you visited before and after visiting our website. That information is not linked to you as an individual unless you create a user profile, but we may keep records of the device being used.

7.3 Social Media

Our websites may also contain plug-ins and other features that integrate third party social media platforms into our websites. You will be able to activate them manually. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.

7.4 Links to Other Websites

If you click on a link found on our websites or on any other website, you should always look at the location bar within your browser to determine whether you have been linked to a different website. This Policy, and our responsibility, is limited to our own information collection practices. We are not responsible for, and cannot always ensure, the information collection practices or privacy policies of other websites maintained by third parties or our service providers where you submit your personal information directly to such websites. In addition, we cannot ensure the content of the websites maintained by these third parties or our service providers, even if accessible using a link from our websites. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.

7.5 Security

Because the security of your personal information is important to us, we use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us. If your browser is SSL enabled (which most are), your transmission of personal information to us online will be encrypted. You can verify whether your personal information is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of your browser window. You can also verify that your personal information will be encrypted using SSL encryption by making sure that the prefix for the web address listed for that page has changed from “http” to “https”. If you do not see the appropriate symbol and the “https” prefix, you should not assume that the personal information that you are being asked to provide will be encrypted prior to transmission.

The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you so that you can take the appropriate actions for the due protection of your rights.

7.6 Minor Children

Our websites do not sell products or services for purchase by children and we do not knowingly solicit or collect personal information from children. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our websites), you may only use our websites with the involvement of a parent or guardian.

For certain locations, we may need to collect personal information regarding minors who will be traveling with the client. This information includes, name, date of birth, and possibly passport information on behalf of the contracted hotel, resort, and tour company or cruise line.

 

7.7 Targeted Advertising

Where permitted by law, we may work with other companies to show you advertisements we think you may find relevant and useful. This may include advertisements displayed on our own websites or apps, or advertisements from us displayed on other companies' websites. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our websites or third-party websites.

8. Choice

You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, services provided by NWS may be affected (for example, we cannot take a hotel reservation or register you for a seminar without a name, contact or payment information).

If you provide us with your contact details (e.g. postal address, email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in. We may also share your personal information with carefully-selected third parties, who may communicate directly with you (e.g. AANA, Baylor Scott and White Health, or other accreditation bodies). In some jurisdictions, data privacy laws may require us to obtain a separate consent before we do so. You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 12 below or following the “unsubscribe” instructions contained in the communications.

If you wish to participate in our Frequent Attendee Point program (FAP) we ask you to indicate your communication preferences. We may also ask you to indicate how you would like to receive any offers, marketing and promotional information (e.g. via email or regular mail) and whether you would be willing to participate in surveys. Once you have indicated your preferences, you can always change them.

In some jurisdictions, in addition to you agreeing to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g. where communications are required in order to fulfill your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws.

We will abide by any request from you not to send you direct marketing materials. When such a request is received, your contact details will be “suppressed” rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.

 

9. Updating or Accessing Your Personal Information

With some limited exceptions, you have rights to access and update personal information held about you. If you want to inquire about any personal information we may have about you, you can do so by sending us a written request by letter or email to the addresses set out in Section 12 below. Please be sure to include your full name, address, telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any personal information regarding you, or in case we need to contact you to obtain any additional information we may require to make that determination.

We reserve the right to charge you a fee, if permitted under applicable law, which is usually around $20USD for processing any such request. When you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially.

You may request that we correct, cancel, and/or stop processing or using personal information that we hold about you. If we agree that the personal information is incorrect, or that the processing should be stopped, we will delete or correct the personal information. If we do not agree that the personal information is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that personal information to be incorrect in the relevant file(s).

10. Changes to this Policy

Just as our business changes constantly, this Policy may also change. To assist you, this Policy has an effective date set out at the end of this document.

 

11. Requests for Access to Personal Information/Questions or Complaints

If you have any questions about this Policy, about the processing of your data described, or any concerns or complaints with regard to the administration of the Policy, or if you would like to submit a request (in the manner described in Section 10 above) for access to or deletion of the personal information that we maintain about you, please contact us by any of the following means:

• by calling the following toll-free number located at the top right of the webpage page on www.northwestseminars.com;

• by mail at Northwest Seminars, Attn: Human Resources, 1412 N 5th Ave, Pasco, WA 99301, United States; or

 

• by emailing your request to info@northwestseminars.com

If you are not satisfied with the response that you receive, you can escalate your concern to the Chief Privacy Officer by sending an email to privacy@northwestseminars.com.

While this Policy alone does not create contractual rights, NWS has ensured compliance with some of its legal obligations in some countries in relation to personal information by creating a set standards and policies.

All requests for access to your personal information must be submitted in writing by letter or email. We may respond to your request by letter, email, telephone or any other suitable method.

Effective Date: May 24, 2018

In the event of any inconsistencies between the English version of this Policy and any version of this Policy in any other language, the English version shall prevail (to the fullest extent permitted under applicable law).