Preparis Inc. (“Preparis”) has adopted this Privacy Shield Policy (“Policy”) to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that Preparis obtains from Individual Customers located in the European Union.
The Federal Trade Commission (FTC) has jurisdiction with enforcement authority over Preparis’ compliance with the EU-U.S. Privacy Shield Policy.
All Preparis employees who handle Personal Data from Europe are required to comply with the Principles stated in this Policy.
Capitalized terms are defined in Section 14 of this Policy.
This Policy applies to the processing of Individual Customer Personal Data that Preparis receives in the United States concerning Individual Customers who reside in the European Union. Preparis provides products and services to businesses.
II. RESPONSIBILITIES AND MANAGEMENT
Preparis has designated the Legal Department to oversee its information security program, including its compliance with the EU-U.S. Privacy Shield program. The Legal Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to firstname.lastname@example.org.
Preparis will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. Preparis personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that Preparis has undertaken to protect Personal Data.
III. RENEWAL / VERIFICATION
Preparis will renew its EU-U.S. Privacy Shield annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
Prior to the re-certification, Preparis will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, Preparis will undertake the following:
C. Ensure that this Policy continues to comply with the EU-U.S. Privacy Shield
D. Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (Preparis may do so through its publicly posted website, Individual Customer contract, or both)
E. Review its processes and procedures for training Employees about Preparis’ participation in the Privacy Shield and the appropriate handling of Individual’s Personal Data
Preparis will prepare an internal verification statement on an annual basis.
IV. COLLECTION AND USE OF PERSONAL DATA
Preparis provides various solutions to Companies (“Clients”) who purchase its products. Preparis collects the Personal Data of the employees of Customers (“Individual Customers”) that purchase its products.
Preparis collects the following types of Personal Data of Individual Customers: contact information, including, a contact person’s name, work email address, work mailing address, work telephone number, personal mobile and home telephone numbers, title, and location.
When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific Customer.
The information that we collect from Individual Customers is used for managing transactions, reporting, invoicing, renewals and other operations related to providing services and products to its Clients.
Preparis uses Personal Data that it collects directly from Individual Customers for the following business purposes, without limitation:
- maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to a Client);
- satisfying governmental reporting, tax, and other requirements (e.g., import/export);
- storing and processing data, including Personal Data, in computer databases and servers located in the United States;
- verifying identity (e.g., for online access to accounts);
- as requested by the Client;
- for other business-related purposes permitted or required under applicable local law and regulation;
- and as otherwise required by law.
V. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
Preparis does not disclose Personal Data to Third Parties. If, in the future this practice changes, Preparis will update this notice and provide individuals with opt-out choice before they data is shared with non-agent third parties. In the unlikely event that Personal Data would be disclosed to a Third Party then Preparis would remain liable under EU-U.S. Privacy Shield.
VI. SENSITIVE DATA
Preparis does not collect Sensitive Data from its Individual Customers.
VII. DATA INTEGRITY AND SECURITY
Preparis uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Preparis has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to Preparis’ electronic information systems requires user authentication via password or similar means. Preparis also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.
Further, Preparis uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.
IX. ACCESSING PERSONAL DATA
Preparis personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
X. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
A. Right to Access. Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which Preparis collected it. All the Personal Data that Preparis stores is provided by our clients from their employee data stores in order to facilitate emergency messaging services. This data is updated routinely via secure data import feeds. Individual Customers may review their own Personal Data stored in our databases by submitting a request to email@example.com. In order to correct or amend any inaccurate data Individual Customers will have to contact their employer. To opt-out of the employer provided emergency messaging Individual Customers will have to contact their employer. To request erasure of their Personal Data, Individual Customers will have to contact their employer.
B. Requests for Personal Data. Preparis will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by public authorities, including to meet national security or law enforcement requirements, unless prohibited by law or regulation; or (b) requests received from the Individual Customer. If Preparis receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract, Preparis will refer such requests to the Individual Customer’s employer.
C. Satisfying Requests for Access, Modifications, and Corrections. Preparis will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
XI. CHANGES TO THIS POLICY
This Policy may be amended from time to time, consistent with the EU-U.S. Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
XII. QUESTIONS OR COMPLAINTS
EU Individual customers may contact Preparis with questions or complaints concerning this Policy at the following address:
XIII. ENFORCEMENT AND DISPUTE RESOLUTION
In compliance with the EU-U.S. Privacy Shield Principles, Preparis commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with questions or concerns about the use of their Personal Data should contact us at: privacyshield@Preparis.com.
If a Customer’s question or concern cannot be satisfied through this process Preparis has further committed to refer unresolved privacy complaints under EU-U.S. Privacy Shield to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus.
If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by Preparis, EU individuals may bring a complaint before the BBB EU Privacy Shield. Information about how to file a complaint before the BBB EU Privacy Shield program can be found at: www.bbb.org/EU-privacy-shield/for-eu-consumers/. Finally, as a last resort and in limited situations, EU individuals may seek redress from the EU-U.S. Privacy Shield Panel, a binding arbitration mechanism.
XIV. DEFINED TERMS
“Individual Customer” means an employee of a client of Preparis from EU.
“Europe” or “European” refers to a country in the European Union.
“Personal Data” as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available.
“Sensitive Data” means Personal Data that discloses a Data Subject’s medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
“Third Party” means any individual or entity that is neither Preparis nor a Preparis employee, agent, contractor, or representative.
Version 1 – January 24, 2017