SurveyConnect EU-U.S. Privacy Shield Privacy Statement

A. NOTICE & CHOICE

1. Affirmative Statement of Participation in the EU-US Privacy Shield Framework
This Statement complies with the EU-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and sharing of personal information transferred from the European Union to the United States. SurveyConnect complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. SurveyConnect has certified that it 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. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

SurveyConnect’s participation in the Privacy Shield applies to all personal information that is subject to the SurveyConnect Privacy Statement and is received from the European Union and European Economic Area. SurveyConnect will comply with the Privacy Shield Principles in respect of such personal information.

SurveyConnect also complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. SurveyConnect has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/swiss

2. Jurisdiction
SurveyConnect is subject to the investigatory and enforcement powers of the Federal Trade Commission.

SurveyConnect’s adherence to the Privacy Shield Principles may be limited to the extent necessary to meet national security, public interest, or law enforcement requirements.

To learn more about the Privacy Shield program, and to view SurveyConnect’s Privacy Shield certification, please visit https://www.privacyshield.gov/.

3. Scope
SurveyConnect’s participation in the Privacy Shield applies to its collection, use, and sharing of commercial data (data that SurveyConnect collects on behalf of its clients or their partners) and internal data (data that SurveyConnect collects for SurveyConnect internal purposes e.g. human resources).


4. SurveyConnect’s Data Collection Processes

SurveyConnect Commercial Data Processing
SurveyConnect provides 360 assessment and survey applications and services to the Human Resource, Talent Management, and OD markets. Our team offers complete support for every phase of 360 survey design, implementation, and analysis.

SurveyConnect End User Data & Privacy Policies
Both SurveyConnect and our clients are responsible for end user privacy. SurveyConnect receives end user data from clients in order to facilitate effective 360-Degree and survey solutions (e.g., name, email address, location). No financial information is ever received from our clients.

SurveyConnect requires that its clients provide the necessary notices and obtain informed consents from their end users.

SurveyConnect Employee & Internal Data & Privacy Policies
SurveyConnect has an employee data and privacy policy. Both SurveyConnect’s employee data and privacy policy and Privacy Shield filing have been submitted to the U.S. Department of Commerce. SurveyConnect employees are aware of and have been trained on this policy, which is also available on the company’s intranet.

B. ACCOUNTABILITY FOR ONWARD TRANSFERS

To effectively process data on behalf of a client to serve the client’s needs, SurveyConnect may need to share that data with certain third parties or sub-processors. In such instances, SurveyConnect will execute any needed contracts, clauses or addendums to ensure that any third-party agents that it engages to process personal data does so in a manner that is consistent with the Privacy Shield Principles. With regard to the Principle of Accountability for Onward Transfer, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

SurveyConnect may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.

C. SECURITY

SurveyConnect uses reasonable and appropriate measures to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account any inherent risks and the nature of the personal data involved.

SurveyConnect is a SaaS company that operates within segregated private datacenters. Data collected by SurveyConnect is co-located in secure locations operated by ViaWest.

D. DATA INTEGRITY & PURPOSE LIMITATION

It is the SurveyConnect client, not SurveyConnect, that determines the “purposes and means” of data processing, include data retention and termination. Under EU law, SurveyConnect is the “data processor” that processes data on instruction from the client or data controller (the entity that determines the “purposes and means” of the data processing in question).

E. ACCESS

You have the right to access your personal information, and to correct, amend or delete such information where it is inaccurate or processed unlawfully, as described in the Privacy Shield Principles. To exercise these rights, please email us at: info@surveyconnect.com.

F. RECOURSE & ENFORCEMENT

In compliance with the EU-US Privacy Shield Principles, SurveyConnect commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Survey Connect at: info@surveyconnect.com.

SurveyConnect has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus, to resolve such complaints at no charge to you. If you do not receive timely acknowledgment of your complaint from SurveyConnect, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address any residual complaints not resolved by other means.

To learn more about the Privacy Shield program, please visit www.privacyshield.gov. To view our certification, please visit www.privacyshield.gov/list.
In compliance with the US-Swiss Safe Harbor Principles, SurveyConnect, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this privacy policy should first contact SurveyConnect, Inc. at: info@surveyconnect.com.

SurveyConnect, Inc. has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Human Resources Data Complaints: If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by SurveyConnect, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”), and for Swiss Data Subjects, the Swiss Federal Data Protection and Information Commissioner (“FDPIC”). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. Survey Connect agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel and the FDPIC.

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