Safe Harbor Privacy Policy
Applications International Corporation ("AIC") respects individual privacy and values the confidence of its customers, vendors, business partners and others. AIC adheres to theSafe Harbor Principles concerning the transfer of personal data from the European Union member countries and Switzerland to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce. For more information on the Safe Harbor Principles please visit http://export.gov/safeharbor/.This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that AIC follows with respect to transfers of personal information anywhere in the world, including transfers from the European Union (EU) and Switzerland to the United States.
Processor on Behalf - AIC provides enterprise compliance management software designed to help companies manage data more effectively. AIC does not own or control any of the information it processes on behalf of the AIC customer. All such information is owned and controlled by the AIC customer. In this capacity, AIC receives information transferred from the EU and Switzerland to the United States merely as a processor on behalf. With the exception of performing data imports or as otherwise directed by its clients, Applications International Corporation does not collect or enter data into its clients’ software systems. At the direction of its clients, Applications International Corporation may transmit data to third parties for interface/integration purposes with third party software products. Any access to or use of client data by Applications International Corporation is incidental to performing Applications International Corporation’s contractual obligations to its clients as a processor.
AIC as a Processor on Behalf - When AIC acts as a processor on behalf of its customer, the policies outlined below apply to all data processing operations concerning personal information that has been transferred from the EU and Switzerland to the United States.
The Safe Harbor is based on the following seven Principles:
1. Notice.
As a data processor for its clients, Applications International Corporation does not inform individuals about the purposes for which their personal information is collected and used by its clients (the individuals’ employers). Applications International Corporation relies on its clients to provide any required notices.
2. Choice.
As a data processor for its clients, Applications International Corporation does not offer individuals a choice regarding the purposes for which their personal information is collected and used by its clients (the individuals’ employers). Applications International Corporation relies on its clients to provide and comply with any required options.
3. Onward Transfer.
Applications International Corporation occasionally transfers personal information to third parties that act as agents for its clients (with regard to interfaces/integrations with third party software products) or for Applications International Corporation (with regard to software implementations). When Applications International Corporation transfers personal information as described above, Applications International Corporation either ascertains that the third party subscribes to the Safe Harbor Principles, is subject to the European Union’s Directive on Data Privacy or another adequacy finding, or enters into a written agreement with the third party requiring the third party to provide at least the same level of privacy protection as is required by the relevant Principles.
4. Security.
Security is extremely important to Applications International Corporation and our clients. Accordingly, Applications International Corporation takes significant security precautions to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Applications International Corporation relies on its clients to establish in the software appropriate password requirements and user roles and levels of access.
5. Data Integrity.
As a data processor for its clients, Applications International Corporation does not typically collect, access or use the personal information provided by its clients. Applications International Corporation relies on its clients (the individuals’ employers) to ensure that personal information is relevant for the purposes for which it is used, reliable for its intended use, accurate, complete and current.
6. Access.
Personal information may be accessed only by authorized users at Applications International Corporation and its clients. As a data processor for its clients, Applications International Corporation believes that individuals should contact their employers to access and review personal information. The burden and expense for Applications International Corporation to identify individuals and provide access for them to correct, amend or delete information would be disproportionate to the risks to the individuals’ privacy, and would possibly violate Applications International Corporation’s contractual obligations to its clients.
7. Enforcement .
AIC utilizes the self-assessment approach to assure its compliance with our privacy statement. AIC periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles. We encourage interested persons to raise any concerns with us using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy. With respect to any complaints relating to this policy that cannot be resolved through our internal processes, we have agreed to participate in the procedures of the panel established by the European Data Protection Authorities and/or the Swiss Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles. In the event that we or the European Data Protection Authorities and/or the Swiss Data Protection Authorities determine that we did not comply with this policy, we will take appropriate steps to address any adverse effects and to promote future compliance. Applications International Corporation notifies and trains appropriate team members regarding its privacy policies and practices and the consequences for failing to comply with them. Any person who we determine is in violation of our privacy policies will be subject to a disciplinary process.
Applications International Corporation notifies and trains appropriate team members regarding its privacy policies and practices and the consequences for failing to comply with them. Any person who we determine is in violation of our privacy policies will be subject to a disciplinary process.
Changes
Applications International Corporation reserves the right to revise this policy at any time in accordance with the Safe Harbor Principles. You agree to be bound by any such revisions and should therefore periodically visit this page to determine the current terms to which you are bound.
Contact Information
If you have any questions regarding our privacy policy, please contact us at: privacypolicy@applicationsinternational.com.
