Applications International Privacy Policy
Applications International Corporation (“AIC”) respects individual privacy and values the confidence of its customers, vendors, business partners and others. AIC adheres to the Privacy Shield Privacy Policy concerning the transfer of personal data from the European Union member countries to the United States of America. Accordingly, we follow the PrivacyShield Principles published by the U.S. Department of Commerce. Privacy Shield 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) to the United States. Applications International Corporation is subject to the regulatory and enforcement authority of the US Federal Trade Commission (FTC).
Applications International Corporation (“AIC”) complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Applications International Corporation (“AIC”) has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms 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, please visit https://www.privacyshield.gov/
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. AIC does not process HR data on its own employees. Applications International Corporation: personal data or PII data is not required nor is it needed for the applications use. It is up to our clients/customers to determine if they are going to provide and use personal data, such as social security and employee name, in the creation of records. All such information is owned and controlled by the AIC customer. In this capacity, AIC receives information transferred from the EU to the United States merely as a processor on behalf of its clients which are made up of various companies and organizations who wish to track safety related incidents. 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. Applications International Corporation does not transmit data to third parties without permission from its clients. Third parties can include, Insurance Carriers clients use for employee injuries. 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 to the United States.
The PrivacyShield is based on the following Principles:
Notice.
Individuals are notified of AIC being a data processor by their employer. In its role as data processor, AIC does not require individuals to provide any PII.
Choice.
As a data processor for its clients, Applications International Corporation will work with individuals (may refer back to our client) 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. Individuals wishing to exercise their choice regarding the processing of their personal data or access their personal data must contact our customer who is also their employer.
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 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. Applications International Corporation may be liable for the third party transfer of personal data.
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.
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 data subjects’ 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.
Access.
Applications International Corporation acknowledges the individual’s right to access their personal data. 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 must refer all individual requests to our client, who remains the data controller.
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.
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.
Note that Applications International Corporation may be required to reveal personal information of European individuals in response to a lawful request by public authorities including to meet national’s security and/or law enforcement requirements.
In compliance with the Privacy Shield Principles, Applications International Corporation 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 Applications International Corporation at:
Lauren Leventer, lleventer@appsint.com
Vice President of Human Resources & Operations
Applications International Corporation has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, 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 http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Finally, and as a last resort under limited circumstances, individuals with unresolved privacy complaints may invoke binding arbitration before a Privacy Shield panel.
Applications International Corporation commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.
Contact Information
Executive Vice President and Policy Officer – Elle Field
If you have any questions regarding our privacy policy, please contact us at: privacypolicy@applicationsinternational.com
Changes
Applications International Corporation reserves the right to revise this policy at any time in accordance with the PrivacyShield 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.