SurveyConnect EU-U.S. Privacy Shield Privacy Statement For EU Personal Data that is Transferred into the US

UPDATED: 04.18.2019

SurveyConnect (we, our, us) is a business-to-business service provider operating and incorporated in the United States. As such, data will be transferred outside your jurisdiction. SurveyConnect’s participation in the Privacy Shield applies to all personal information that is subject to the SurveyConnect General Privacy Statement and is received into the United States from the European Union and European Economic Area (EU Personal Data). SurveyConnect will comply with the Privacy Shield Principles in respect of such personal information.

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).

SurveyConnect’s relationship to the data we handle is determined by the circumstances under which we obtain and manage that information.

SurveyConnect As A Data Controller

Representatives of business wishing to utilize our services can fill out a form or survey on our website. The information we collect in this manner may consist of, but not be limited to, personal name, company name, business address, phone and email information. We may also receive corporate financial data relevant to the payment for our services. We do not store financial data on our site or servers. We remain the data controller for this information and utilize it to pursue the desired business relationship. We also retain control of all data belonging to our employees.

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. Once a business has contracted to utilize our services, they can design their own criteria and either input the data of their employees directly into the system or contract us to do it for them. We are a data processor in relation to this data and are not authorized to make any independent judgements in relation to it, or independently share it, with any third parties.

A. NOTICE & CHOICE

Affirmative Statement of Participation in the EU-US Privacy Shield Framework 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 transferred to the United States pursuant to Privacy Shield. SurveyConnect has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under 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 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.

SurveyConnect End User Data & Privacy Policies

SurveyConnect receives end user data from clients in order to facilitate effective 360-Degree and survey solutions for their employees (e.g., name, email address, location, demographic information relating to individual tasks or positions). No financial information is ever received from our clients.

As a data processor we are not authorized to provide end-user access or assist in the correction, erasure, or editing of any EU employee data provided by our client companies. SurveyConnect requires that its clients provide the necessary notices and obtain informed consents from their end users. An EU individual wishing to exercise their right to access and/or control their data must refer to our customer, who remains the data controller.

Limiting Use and Disclosure of Personal Data

Personal data will not be used or disclosed by SurveyConnect for purposes other than those for which it was collected. If SurveyConnect changes this practice, individuals will be informed and provided with choices to limit use and disclosure of their personal information. SurveyConnect may share personal information as required or permitted by law.

If an individual has submitted data to SurveyConnect and wishes to have the information destroyed, the individual may contact SurveyConnect at info@surveyconnect.com requesting its destruction. If we are the data controller for that data, SurveyConnect will make reasonable efforts to securely remove the data from its systems. If we are the data processor, SurveyConnect may have to refer the request to our client, who remains the data controller.

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. ONWARD TRANSFERS

SurveyConnect does not ever sell or make available personal information about our customers to third-parties. If this practice should change in the future, we will amend this policy to identify the parties and purposes for the sharing and instruct individuals as to how they can limit the use of their data.

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.

Pursuant to the Privacy Shield Framework SurveyConnect remains liable for the onward transfer of EU personal data unless we can prove we were not a party to the events giving rise to the damages.

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. Note that if you are inquiring about data we handle in our capacity of processor, we will have to forward your request to our client company, who maintains control of that information.

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 SurveyConnect 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.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

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