The Cultural Navigator online learning platform, which is managed and owned by Berlitz, is announcing updates to its data security system.

1. What is PII user data?

The data referred to in this document is Personally Identifiable Information (PII). This is any data specifically associated with an individual user, such as their name, username-email address, password and their Cultural Orientations Indicator (COI) report.

2. Is user information protected from theft?

Yes, the Cultural Navigator is certified by TRUSTe and the International Safe Harbour Principles. These certifications mean users’ PII is guaranteed protected, and the Cultural Navigator will not share this information with any third parties. After a user’s account expires, their information is deleted permanently from the Cultural Navigator database.

3. Why is the Cultural Navigator moving PII to servers in different world regions?

In April 2016, the European Union announced an important change to its General Data Protection Regulation (GDPR) regarding the security of European Internet users’ PII. The Berlitz Cultural Navigator team has proactively initiated a project to fall in compliance with the updated GDPR, and will establish a server in the EU to house the PII of users who are affiliated with Europe-based clients that have Cultural Navigator license agreements. All other users’ PII will be housed on the general server.

In addition, having the EU server geographically closer to the end users in Europe will reduce latency and improve performance.

4. Why was this change necessary?

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) by the European Commission details regional PII requirements, which the Cultural Navigator is adhering to.

5. What happens to users’ PII once the EU server is live?

When the EU server goes live, users whose companies hold a Cultural Navigator license agreement will have their PII moved to the EU server.

6. What if a company is based outside of Europe but has employees who live and work in the EU?

The server that users’ PII is housed on does not depend on where the users themselves are located, but rather where their companies, which hold a Cultural Navigator license, are located

7. Will users in any region see a disruption in their access to their Cultural Navigator accounts?

No, users should see no changes at all to their Cultural Navigator accounts. However, if a user experiences any difficulties accessing their account, they may contact helpdesk@tmcorp.com.

8. If a Europe-based Cultural Navigator user travels outside of the EU, will they still be able to access their Cultural Navigator account?

Yes, users whose PII is housed on the EU server can access their Cultural Navigator account from anywhere in the world.

9. Do users based in the EU need to make any changes on their end?

Users whose PII is being moved to the EU server will not need to make any changes in order to access their accounts.

10. Who will have access to a user’s PII?

The user, their license group’s COA-certified practitioner, and authorized Berlitz Online Solutions personnel will have access to a user’s PII. COA-certified practitioners who have access to a user’s PII will only be able to see the user’s name, email address and COI results. The COA practitioner will never have access to a user’s password or any additional data.

11. Can COA practitioners access their international users’ information?

In order to access a user’s information, COA practitioners will have access the practitioner application for the user’s region. For instance, if a practitioner logs into the EU practitioner application (https://eupractitioner.culturalnavigator.com) they will only have access to user information that is housed on the EU server. To access user information for other users, the practitioner must access the general server (https://practitioner.culturalnavigator.com).

12. Is there a separate helpdesk for the EU region?

There is only one helpdesk to answer all user inquires: helpdesk@tmcorp.com