Last revision of 21 January 2025

PSI CRO AG as a data controller (“PSI”, “we”), is responsible for the processing of your personal information (“personal data”) that you provide to PSI when you interact with PSI Learning Pool. This Policy describes how we collect, use, disclose, store and otherwise process personal data of individuals who visit this educational platform.

Our global data protection program is built to achieve compliance with the applicable data protection laws, including Regulation (EC) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and the Swiss Federal Act on Data Protection.

FOR WHICH PURPOSES AND WHICH OF YOUR PERSONAL DATA DO WE PROCESS?

We will collect and process the below listed personal data for the indicated purposes:

• To create a user account and enable you to interact with the educational materials and elements of the platform, we will need your identification and contact data (name, surname address, email address, phone number), user data (username, password).
• To ensure that the platform is secure, we will need to collect your user data and metadata (username, password, IP address, device type, user activity on the platform, dates and time of operations on the platform).
• To facilitate payments for your selected courses and to make sure we maintain accountability for the received payments, we will need to collect and share with a payment service provider your identification and contact data (name, surname, address, email address, phone number), your courses and related fees, payment method, dates of payments.

To be able to provide you with the option to pay via the platform and to make your navigation experience seamless, we need to use cookies. Cookies are pieces of data that a website transfers to a user’s computer connected to the Internet. Cookies will enable PSI to identify the user of the website by the domain name, user’s internet service provider, operating system, and the date and time the user visited our website. PSI shall not seek for additional information to identify users beyond this. We use only necessary functional cookies and do not use statistical and marketing cookies.

For more information, please review our Cookie Notice.

WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

• As this educational module is a service that you request from us and that we provide to you for a fee, we will mainly rely on the necessity to process personal data for fulfilling our obligations to you under this arrangement. 
• We need to ensure information security and availability of PSI Learning Pool. When we collect and use your personal data in this context as explained in the section above, we will rely on our legitimate interest. 

WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

• Personal data that PSI obtains via this website will be available to PSI staff members responsible for its maintenance and administration of this platform.
• To enable your payments via our platform, we established smooth connection with the portal of our payment service provider PayPal

We will not receive bank information. These data will be obtained from you directly by PayPal. Please read PayPal Privacy Statement to learn how our partner processes your payment information.

WILL DATA BE TRANSFERRED ABROAD?

PSI is a global company with affiliates worldwide. This mean that PSI members responsible for this platform may be located worldwide. Our payment provider PayPal is located in the USA.

When the recipients of your data are located abroad, information about you will need to be sent or/and accessed from abroad, including to/from countries where the personal data protection laws may be less strict as compared to your home country. However, PSI takes appropriate steps to protect your personal data.

HOW DO WE PROTECT PERSONAL DATA?

PSI makes reasonable efforts to ensure that these PSI staff and third-party service providers commit to protect your personal information to the same level as PSI does, regardless of their location. Such efforts include technical and organizational measures, as well as may consist in contractual protections to safeguard your personal information. You can ask PSI to tell you more about these safeguards, including a review of any applicable protective measures.

PSI employs reasonable organizational and technical safeguards to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction.

FOR HOW LONG DO WE KEEP PERSONAL DATA?

We shall retain personal data for no longer than is necessary to follow our standard procedures, to reach our commercial goals with the consideration of your rights and our business interests, and to fulfill our obligations by laws, contracts and any regulations that may apply to PSI’s business activities. In some cases, we may envisage removal of personal data earlier than our procedures and practices require. For example, if we receive a data erasure request from an individual whose data we process.

YOUR RIGHTS REGARDING CONTROL OF YOUR PERSONAL DATA AND HOW YOU CAN EXERCISE YOUR RIGHTS

You have the right to request access to, rectification or erasure of your personal data, restriction of processing, as well as object to processing in some cases.

If you are based in the EU, you have the right to lodge a complaint to the supervisory authority. You will find your national data protection authorities and their contact details following this link. If the national data protection authority is not on the list, please reach out to PSI Data Protection at privacy@psi-cro.com to ask about the appropriate point of reference in your country

HOW TO ASK QUESTIONS ABOUT DATA PRIVACY AND PERSONAL DATA PROTECTION?

You can email your enquiries, as well as regarding your data protection rights to PSI Data Protection at privacy@psi-cro.com