Safe Harbor Privacy Policy for Consumer Data

Decision Software, Inc., (“DSI”) 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. This Safe Harbor Privacy Policy sets forth the privacy principles that DSI follows with respect to personal consumer information transferred from the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.

DSI complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor 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 and Switzerland. DSI has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, please visit http://www.export.gov/safeharbor/.

Safe Harbor

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, DSI adheres to the U.S.-EU and U.S.-Swiss Safe Harbor Principles (hereinafter “Safe Harbor Principles”).

Scope

This Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received from consumers by DSI in the United States from the European Economic Area and 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 DSI and solely for DSI’s Clients, or to which DSI discloses personal information for use on behalf of DSI’s Clients.

“DSI” means Decision Software, Inc., its successors, subsidiaries, divisions and groups in the United States.

“Clients” are companies that are customers of DSI that interact with or market to Consumers.

“Consumer” means an individual located in the European Economic Area or Switzerland.

“Personal Information” means any information or set of information that identifies or is used by or on behalf of DSI 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, or trade union membership, or that concerns health or sex life. In addition, DSI 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 are based on the Safe Harbor Principles.

NOTICES:

  • DSI does not directly interact with Consumers. Instead, DSI provides services for its Clients.
  • DSI does not collect, store, or accept Sensitive Personal Information pertaining to Consumers.
  • Occasionally DSI utilizes services provided by Agents who will have access to Personal Information in order to provide services to you on DSI Client’s behalf. Agents are not permitted to use your Personal Information for their own purposes, and DSI requires its Agents to subscribe to the Safe Harbor Principles.
  • Where DSI receives Personal Information from its Clients, DSI 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.

CHOICE: DSI will offer Consumers the opportunity to choose (opt-in) 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. DSI will provide Consumers with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: DSI will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the Consumer. DSI will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current. DSI 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.

TRANSFERS TO AGENTS: DSI 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 or Safe Harbor certification. Where DSI has knowledge that an Agent is using or disclosing personal information in a manner contrary to this Policy, DSI will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, DSI will grant individuals reasonable access to personal information that it holds about them. In addition, DSI 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 DSI’s Safe Harbor Officer via phone, email, or mail using the contact information provided below.

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

ENFORCEMENT: DSI will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that DSI determines intentionally violates this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to DSI’s Safe Harbor Officer at the address given below. DSI 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. For complaints that cannot be resolved between DSI and the complainant, DSI agrees to participate in the dispute resolution procedures of the JAMS International Mediation Rules pursuant to the Safe Harbor Principles.

Limitations on Application of Principles

Adherence by DSI to these Safe Harbor 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.

Internet Privacy

DSI sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers. DSI 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. DSI’s Internet Privacy Policy can be found athttp://www.dsimarketingservices.com/privacy-policy.php.

Contact Information

Questions or comments regarding this Policy should be directed to DSI’s Safe Harbor Officer using one of the following methods:

Mail

Decision Software, Inc.
6911 Old Landover Rd.
Landover, MD 20785

Email

safeharbor@dsoftware.biz

Telephone

(301) 459-9000

Changes to this Safe Harbor Privacy Policy

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the DSI web page (www.dsimarketingservices.com/) for 60 days whenever this Policy is changed in a material way.

Effective Date: December 15, 2014

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