Why We Process Your Personal Information
The Website provides access to resources and training focusing on the early intervention models to increase attachment and security by Glen Cooper, Kent Hoffman, and Bert Powell. Facilitators meeting specific training criteria are able to provide trainings using the Website and are listed within a directory of Registered COSP Facilitators. This opt-in directory allows Facilitators to make their name, location, areas of interest, and language publicly available solely for the purpose of arranging trainings. Facilitators also have user accounts on the Website, which are used to administer the directory. User profiles also include basic contact information, including an email address for each user. If you do not agree to the terms of this Policy, please do not use the Services.
We will also collect your personal information for training or learning event registration purposes, and for purposes of shipping materials post-training. This information may include your name, occupation, company name, email address, physical address, and telephone number. Upon completion of the learning event, your personal information and event registration and completion history will be stored in our cloud-based, secure CRM platform, Oracle NetSuite. These records will not be released without your consent or issued to any external party. However, the funding entity who has paid for your registration may request COMPLETION records for your learning event.
Information We Process to Provide the Services
Providing user accounts and maintaining an online directory of Facilitators requires access to personal data. If you request a user account, we require a password and your basic contact information, including your name, email address, street address, and phone number. We may also ask you to submit and we may process data that is personal to you, including your age, gender, and geographic location. We receive and store this information and use it to create a user profile and provide you with services. Upon your request, we include your name, location, area of interest, and language within the directory. We may use your e-mail address or mobile phone number to contact you about your experience with the Services and notify you about company news and promotions.
When you use a mobile platform to access the Services, we may collect and record certain information such as your unique device ID, hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), and your location (based on your Internet Protocol (“IP”) address). This information is useful to us for troubleshooting and helps us understand usage trends and for providing you with the correct version of the application.
We may also receive information about you if your information is provided to us by a Facilitator. Upon successful completion of a training, attendance records, email verification, and contracts from your training are processed by Circle of Security International when determining whether creation of your account is authorized.
Data Privacy Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area, you have the following rights with respect to your personal data:
- Right of Access – a right to understand the nature and extent of how your data is processed;
- Right to be Rectification – a right to request correction of inaccurate data;
- Right to Erasure – a right to request erasure of personal data in some circumstances, commonly referred to as the “Right to be Forgotten”;
- Right to Restriction of Processing – a right to limit how your personal data is processed;
- Right to Data Portability – a right to receive personal data and transfer information to another controller;
- Right to Object – a right to object to processing of your personal data based on your circumstances and a right to object to direct marketing; and
- Right to Freedom from Automated Decision-making – a right not to be subject to decision-making based solely on automated processing, including profiling, that produces significant effects.
Circle of Security International will take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data. Please contact us if you wish to learn what personal data we hold about you or would like to request deletion of your personal data. Once we have verified your identity, we will comply with all reasonable requests.
You may bring a complaint directly to us by emailing us at info[at]circleofsecurityinternational[dot]com. We take all of your concerns seriously and will review any written complaints received by us. We will cooperate with the appropriate regulatory authorities to resolve any complaints regarding your personal data.
You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
Why We Process Your Personal Information
The following list identifies why Circle of Security International uses your personal information when providing the Services:
- Directory. The Directory provides a publicly accessible, opt-in list of registered COS-P Facilitators. Facilitators are not added to the map or listing unless the Member actively creates a directory listing. To create a directory listing, go to the “Members” page located in the navigation side-bar. Click the “Directory Edit” button at the bottom of the Members page to enter your listing information. Click “Save” once you have finished entering your information in the form provided. You will be prompted with a consent form before final submission. By default, each directory listing remains active indefinitely unless removed by the user via the Website or unless such removal is requested by the user. You may request removal by emailing us at info[at]circleofsecurityinternational[dot]com.
- User Accounts. User accounts allow Circle of Security International to provide users of the site with the ability to access a members-only portion of the website. Users with accounts may also submit their name, location, area of interest, and language to the publicly accessible directory of COS-P Facilitators.
- Customer Surveys & Research. We may use your contact information to ask you about your experience and about your use of the Services. We use this feedback to improve our Services.
- Event Registration. We store the required personal information related to your participation as a learner in any of our in-person or online learning events.
- Marketing. We use your information when developing and providing relevant marketing materials. Our goal is to only provide you with materials that are of interest to you. We provide marketing materials to our users, including direct emails and other written materials. You may opt out of direct marketing communications by either clicking “unsubscribe” within any emails sent, or requesting removal by emailing us at info[at]circleofsecurityinternational[dot]com. We will not provide or sell your information to any third party.
- Detecting and Preventing Fraud. We use your information to monitor for potentially fraudulent activities committed using the Services.
Our Legal Bases for Processing Personal Information
Consent. We value your privacy and therefore rely on your informed, opt-in consent before including your personal data within the publicly accessible directory for purpose A. Users may withdraw consent at any time and consent is not required to otherwise use the Services.
Legitimate Interests. Our use of your information is necessary for our legitimate interests under purposes B - G. We have a legitimate interest in providing an excellent user experience and we would be unable to provide Members with secure access to the members-only area or provide notifications to users relating to trainings or workshops without access to their personal information. We also have legitimate interests in providing customer support, evaluating and improving our Services (via Service Usage Statistics or direct customer feedback), and in detecting and preventing fraud, which helps protect us and our customers from harm. We value your fundamental rights and freedoms and therefore do not engage in uses of your information where our legitimate interests are outweighed by your fundamental rights and freedoms.
Legal Obligations; Vital Interests. In addition to the specific bases for disclosure of personal data set forth in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. To the extent we are legally required to disclose information to law enforcement, we will comply with such requests. We will not otherwise voluntarily disclose your information.
Personal Information Collected By Circle of Security Within the Preceding 12 Months
Over the past 12 months, Circle of Security has collected information concerning users’ names, addresses, email addresses, citizenship, usernames, User Content, use of the Service, IP addresses, MAC addresses, IMEI, browsers, devices, operating systems, and survey responses.
Where and How is my Personal Information processed?
Circle of Security is located on the West Coast of the United States. Circle of Security International uses the services of the following processor when providing the Website:
- Digitimber (United States)
- Digitimber is located in the United States of America and provides the server infrastructure for Circle of Security International.
Transfers of Personal Data
Pursuant to the GDPR, all transfers of personal data are subject to either (i) an adequacy decision, or (ii) appropriate safeguards.
How long does Circle of Security International retain my Personal Information?
We will retain your personal information for a minimum of seven (7) years or the period necessary to fulfill the purposes outlined in this Agreement unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes.
Can I Limit Circle of Security International’s Processing of my Personal Information? Can I Request Deletion of my Personal Information?
Yes, you may limit our processing of your data or request deletion by contacting us at info[at]circleofsecurityinternational[dot]com. However, if compliance with your request would prevent Circle of Security International from being able to provide the Services to you, then compliance with your request may require cancellation of any upcoming trainings or workshops arranged using the Website.
Does Circle of Security International Process the Personal Information of Children?
Circle of Security International requires that all of its users be over 18 years of age. If you have concerns or believe Circle of Security International may have received personal information relating to a person under the age of 18, please contact us at info[at]circleofsecurityinternational[dot]com.
How can I Access my Information? Can I Request a Correction?
Yes, you may obtain a copy or request a correction of your personal information by emailing info[at]circleofsecurityinternational[dot]com. You may also contact applicable regulatory authorities regarding our processing of your personal information.
Does Circle of Security International use my Personal Information for Automated Decision-Making?
Circle of Security International does not rely on fully automated decision-making.
California Consumer Privacy Act of 2018
If you are a California resident, you may have additional privacy rights regarding your personal data. These rights include the right to request disclosure of the categories of information collected, why that information is collected, and the types of third parties receiving access to your information. You may also request deletion of your data and obtain information relating to any sharing of information with third parties.
To the extent possible, users will receive equal service and price regardless of whether they exercise their privacy rights under the California Consumer Privacy Act of 2018. Circle of Security International does not sell the personal data of its users.
You may contact us regarding these rights by emailing us at info[at]circleofsecurityinternational[dot]com.
Usage Statistics & Tracking
Cookies. Cookies are small text files that that are transferred to your computer and/or device to remember things about your visit, such as your preferences or a user name and password. Information contained in a cookie may be linked to your personal information for purposes such as improving the quality of the Service or tailoring recommendations to your interests. You can disable cookies at any time, although it may prevent you from accessing or using some or all features of the Services.
Web Beacons. A “Web Beacon” is an object that is embedded in a web page that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page. Circle of Security International may use Web Beacons with the Services to count users who have visited particular pages and to deliver co-branded services. Web Beacons are not used to access users’ personally identifiable information; they are a technique Circle of Security International may use to compile aggregated statistics about usage of the Services. Web Beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides.
You may not decline Web Beacons. However, they can be rendered ineffective by declining all cookies or modifying your browser setting to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis. Third parties are not permitted to use Web Beacons with the Services.
COSI Personnel and Your Records