EU-US PRIVACY SHIELD
Tasseologic, Inc., (“Tasseologic”) is committed to upholding the highest ethical standards in its business practices and strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business. The EU-US Privacy Shield sets forth the privacy principles that Tasseologic follows with respect to personal consumer information transferred from the European Union (EU) to the United States.
Tasseologic 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 from European Union member countries. Tasseologic has certified that it adheres to the Privacy Shield Principles of notice; choice; onward transfer; security; data integrity and purpose limitation; access; and recourse, enforcement and liability. To learn more about the Privacy Shield Program, please visit https://www.privacyshield.gov.
The EU-U.S. Privacy Shield Framework was designed by the U.S. Department of Commerce and European Commission to provide companies on both sides of the Atlantic with a mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States in support of transatlantic commerce.
The Privacy Shield Framework provides a set of robust and enforceable protections for the personal data of EU individuals. The Framework provides transparency regarding how participating companies use personal data, strong U.S. government oversight, and increased cooperation with EU data protection authorities (DPAs).
The European Commission deemed the Privacy Shield Framework adequate to enable data transfers under EU law.
This Privacy Shield Policy (the “Policy”) applies to all personal information received from consumers by Tasseologic in the United States from the EU any format including electronic, paper or verbal.
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party, acting as a controller, that collects or uses Personal Information under the instructions of Tasseologic and solely for Tasseologic’s Clients, or to which Tasseologic discloses personal information for use on behalf of Tasseologic’s Clients.
“Tasseologic” means Tasseologic, Inc., its successors, subsidiaries, divisions and groups in the United States.
“Clients” are companies that are customers of Tasseologic that interact with or market to Consumers.
“Consumer” means an individual located in the EU or Switzerland.
“Personal Information” means any information or set of information that identifies or is used by or on behalf of Tasseologic 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, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Tasseologic will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.
“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Processing” of personal data means any operation or set of operations which is performed upon personal data, whether or not by automated means such as collection, recording, organization, storage, alteration, retrieval, consultation, use, disclosure/ dissemination, and erasure/destruction.
The privacy principles in this Policy are based on the following Privacy Shield Principles.
- Tasseologic participates in the Privacy Shield and complies with its Principles. https://www.privacyshield.gov
- Tasseologic does not directly interact with Consumers. Instead, Tasseologic provides services for its Clients. Tasseologic does not collect, store, or accept Sensitive Personal Information pertaining to Consumers.
- Occasionally, Tasseologic utilizes services provided by Agents who will have access to Personal Information in order to provide services for Tasseologic Client’s behalf. Agents are not permitted to use your Personal Information for their own purposes, and Tasseologic requires its Agents to subscribe and adhere to the Privacy Shield Principles. Any agent performing processing on behalf of Tasseologic is under contractual obligations. Tasseologic will take reasonable and appropriate steps to ensure their processing follows these Principles.
- Where Tasseologic receives Personal Information from its Clients, Tasseologic will use and disclose such information only in accordance with the notices provided by such Clients and the choices made by the Consumers to whom such Personal Information relates.
- Tasseologic’s independent dispute organization is the DMA.
CHOICE: Tasseologic will offer Consumers 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 Consumer. Tasseologic will provide Consumers with reasonable mechanisms to exercise their choices.
TRANSFERS TO AGENTS: Tasseologic will obtain assurances from its Agents that they will safeguard personal information consistently with this Policy and must comply with the Notice and Choice Principles. 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 Shield Principles certification. In addition, Agents will only collect and store Personal Information that is relevant to fulfill the purpose of the request and will retain such information no longer than appropriate to fulfill the purpose of that request.
Where Tasseologic has knowledge that an Agent is using or disclosing personal information in a manner contrary to this Policy, Tasseologic will take reasonable and appropriate steps to stop and remediate the processing. Upon request, Tasseologic will provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department.
SECURITY: Tasseologic will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
DATA INTEGRITY AND PURPOSE LIMITATION: Tasseologic will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the Consumer. Tasseologic will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current. Tasseologic will only collect and store Personal Information that is relevant to fulfill the purpose of the request and will retain such information no longer than appropriate to fulfill the purpose of that request.
ACCESS: Upon request, Tasseologic will grant individuals reasonable access to personal information that it holds about them. In addition, Tasseologic will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. These requests can be made by contacting Tasseologic’s Privacy Shield Officer via phone, email, or mail using the contact information provided below.
RECOURSE, ENFORCEMENT AND LIABILITY: Tasseologic will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee or agent that Tasseologic determines intentionally violates this policy will be subject to disciplinary action up to and including termination of employment and/or contract.
In addition, where Tasseologic has knowledge that an Agent is using or disclosing personal information in a manner contrary to this Policy, Tasseologic will take reasonable and appropriate steps to stop and remediate such processing. Upon request, Tasseologic will provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department.
DISPUTE RESOLUTION: There is a measured process in place for addressing any concerns. It is as follows along with the order of precedence:
- Any questions or concerns regarding the use or disclosure of personal information should be directed to Tasseologic’s Privacy Shield Officer at the address given below. Tasseologic will expeditiously respond, investigate, and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy at no cost to the individual.
- For complaints that cannot be resolved between Tasseologic and the complainant, Tasseologic agrees to participate in the dispute resolution procedures of the DMA Privacy Shield for dispute resolution pursuant to the Privacy Shield Principles. There is no fee incurred with this process either. They may be reached via the following:
Direct Marketing Association
Attn: Privacy Shield/Safe Harbor Line
1615 L Street NW, Suite 1100
Washington, D.C. 20036
To file an online complaint with DMA: https://thedma.org/resources/consumer-resources/eu-u-s-privacy-shield-u-s-swiss-safe-harbor-program-for-consumers/the-dma-privacy-shield-program-consumer-complaint-form/
3. Binding arbitration. This is available to an individual to determine whether Tasseologic has violated its obligations under the Principles and whether any such violation remains fully or partially unremedied. The Privacy Shield Panel has the authority to impose individual-specific, non-monetary relief.
LIMITATIONS ON APPLICATION OF PRINCIPLES
Adherence by Tasseologic to these Privacy Shield Principles may be limited (a) to the extent required or permitted by law or legal process, such as to respond to or investigate a legal or ethical obligation or request or pursuant to court orders, subpoenas, interrogatories or similar directive carrying the force of law; and (b) to the extent expressly permitted by an applicable law, rule or regulation.
Questions or comments regarding this Policy should be directed to Tasseologic’s Privacy Shield Officer using one of the following methods:
CHANGES TO THIS PRIVACY SHIELD POLICY
This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles. A notice will be posted on the Tasseologic web page https://tasseologic.com/ for 60 days whenever this Policy is changed in a material way.
July 20, 2016