Privacy Shield Policy
Company recognizes that the EU has established strict protections regarding the handling of EU Personal Data, including requirements to provide adequate protection for EU Personal Data transferred outside of the EU. To provide adequate protection for certain EU Personal Data about clients, suppliers, business partners, job applicants and employees received in the US, Company has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (“Privacy Shield”). Company adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.
For purposes of enforcing compliance with the Privacy Shield, Company is subject to the investigatory and enforcement authority of the US Federal Trade Commission and US Department of Transportation. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at https://www.privacyshield.gov. To review Company’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at https://www.privacyshield.gov/list.
Personal Data Collection and Use
We may collect the following categories of sensitive EU Personal Data: contact information, financial information and HR information. When we collect sensitive EU Personal Data, we will obtain your opt-in consent where the Privacy Shield requires, including if we disclose your sensitive EU Personal Data to third parties, or before we use your sensitive EU Personal Data for a different purpose than we collected it for or than you later authorized.
Data Transfers to Third Parties
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EU Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Company maintains reasonable and appropriate security measures to protect EU Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
You may have the right to access the EU Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EU Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your EU Personal Data to us at email@example.com. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EU Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with the EU data protection authorities. If you are unsatisfied with the resolution of your complaint, you may contact the EU data protection authorities at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for further information and assistance.
Binding Arbitration You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Company and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).
If you have any questions about this Policy or would like to request access to your EU Personal Data, please contact us as at firstname.lastname@example.org.
Changes To This Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.
Effective Date: January 1, 2017
Last modified: January 1, 2017