EU-U.S. Privacy Shield Framework

Configio 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.  Configio 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/

In compliance with the EU-US Privacy Shield Principles, Configio 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 Configio at: privacy@configio.com

Configio has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles 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. If you do not receive timely acknowledgment of your complaint, 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.

For complaints left unresolved by all other available channels, individuals may invoke binding arbitration before a Privacy Shield Panel.

 

US-Swiss Safe Harbor

Configio 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.  Configio 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/

In compliance with the US-Swiss Safe Harbor Principles, Configio 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 Configio at:  privacy@configio.com

Configio 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.

This Safe Harbor Privacy Policy Statement (the “Policy”) applies to all personal information received by Configio in the United States from Switzerland, in any format, including electronic, paper or verbal.

 

Definitions

For purposes of this Policy, the following definitions shall apply:

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Configio or to which Configio discloses personal information for use on Configio’s behalf.

“Configio” means My Custom IT LLC, its predecessors, successors, subsidiaries, divisions and groups in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of Configio to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Configio will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

 

Privacy Principles

The privacy principles in this Policy have been developed based on the EU-U.S. Privacy Shield Framework and the US-Swiss Safe Harbor Framework.

 

Notice

Configio is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Configio may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Where Configio collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which Configio discloses that information, the choices and means, if any, Configio offers individuals for limiting the use and disclosure of personal information about them, and how to contact Configio. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Configio, or as soon as practicable thereafter, and in any event before Configio uses or discloses the information for a purpose other than that for which it was originally collected.

Where Configio receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

 

Choice

Configio will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Configio will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Configio will provide individuals with reasonable mechanisms to exercise their choices.

 

Data Integrity

Configio will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Configio will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

 

Transfers To Agents

Configio will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Privacy Principles, certification by an agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Configio has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Configio will take reasonable steps to prevent or stop the use or disclosure.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Configio is potentially liable.

 

Access and Correction

Configio provides individuals the right to access personal information that it holds about them. In addition, Configio will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.  In most cases personal information can be accessed and modified by the individual by logging into their account and self-managing their personal information. In an instance where the specific personal information cannot be self-managed the individual should contact the site administrator for support.

 

Security

Configio will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

 

Enforcement

Configio will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Configio determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

 

Limitation on Application of Principles

Adherence by Configio to these privacy principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

 

Internet Privacy

Configio sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers. Configio recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the “IPP”) governing the treatment of personal information collected through web sites that it operates. With respect to personal information that is transferred from the European Economic Area or Switzerland to the U.S., the IPP is subordinate to this Policy. However, the IPP also reflects additional legal requirements and evolving standards with respect to Internet privacy. Configio’s Internet Privacy Policy can be found at http://configio.com/privacy-policy/.

 

Contact Information

Questions or comments regarding this Policy should be submitted to the Configio Privacy Office by mail to:

Configio
1421 N Mullan Suite A
Spokane Valley, WA 99206

Or by e-mail to privacy@configio.com

 

Changes to Privacy Policy

This Policy may be amended from time to time, consistent with the requirements of the EU-US Privacy Shield Framework and US-Swiss Safe Harbor Principles.

 

EFFECTIVE DATE: August, 2016