Configio has further committed to refer unresolved privacy complaints under the U.S.-EU and U.S.-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, 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.
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles (the “U.S.-EU Safe Harbor Principles”) and frequently asked questions (collectively the “U.S.-EU Safe Harbor Framework”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. The EEA also has recognized the U.S. Safe Harbor as providing adequate data protection. The United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of data protection principles (the “U.S.-Swiss Safe Harbor Principles”) and frequently asked questions (collectively the “U.S.-Swiss Safe Harbor Framework) to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States. Consistent with its commitment to protect personal privacy, Configio adheres to the U.S.-EU and U.S.-Swiss Safe Harbor Principles (hereinafter “Safe Harbor Principles”).
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.
The privacy principles in this Policy have been developed based on the Safe Harbor Principles.
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.
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.
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 Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the 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.
Access and Correction
Upon request, Configio will grant individuals reasonable access to 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.
Configio will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
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.
Configio has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, 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.
Limitation on Application of Principles
Adherence by Configio to these Safe Harbor 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.
Questions or comments regarding this Policy should be submitted to the Configio Privacy Office by mail to:
1421 N Mullan Suite A
Spokane Valley, WA 99206
Or by e-mail to firstname.lastname@example.org
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles.
EFFECTIVE DATE: April, 2015