ForeSoft is committed to protecting the privacy of your Personal Information (as defined below). We respect individual privacy and value the trust of our customers and employees, consumers, patients, health care providers, business partners and others who provide their Personal Information to us. This EU-U.S. Privacy Shield Policy (the “Policy”) sets forth the privacy principles that ForeSoft follows with respect to transfers of personal information from the European Union to the United States, and is intended to give you confidence in the privacy and security of your Personal Information when accessing the available pages on any of the following ForeSoft websites (collectively, the “Site”):
The Site provides you with information about ForeSoft and our services and products. ForeSoft collects data to operate effectively and provide you the best experiences with our services and products.
COMPLIANCE WITH PRIVACY SHIELD PRINCIPLES
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the “EU-U.S. Privacy Shield 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 U.S.
We recognize that the European Community has established a data protection regime which applies to the European Economic Area (“EEA”) and restricts companies in the EEA in transferring personal data about individuals in the EEA to the U.S., unless there is “adequate protection” for such personal data when it is received in the U.S. To create such “adequate protection,” ForeSoft adheres to the EU-U.S. Privacy Shield Framework published by US Department of Commerce (“EU-U.S. Privacy Shield Principles”) with respect to personal data about individuals in the EEA that we receive from our customers and other business partners. ForeSoft’s EU-U.S. Privacy Shield Certification also extends to data that we receive directly through ForeSoft’s publicly accessible Site via secure form submission.
ADHERENCE TO SEVEN PRIVACY SHIELD PRINCIPLES
The privacy principles in this Policy have been developed based on the EU-U.S. Privacy Shield Principles.
NOTICE: Where ForeSoft collects Personal Information (as defined below) directly from individuals in the EEA, we will inform them about the purposes for which we collect and use personal information about them, the types of non-agent third parties to which we disclose that information, the choices and means, if any, we offer individuals for limiting the use and disclosure of personal information about them, and how to contact us. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to ForeSoft, or as soon as practicable thereafter, and in any event before ForeSoft uses or discloses the information for a purpose other than that for which it was originally collected.
Where ForeSoft 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. “Personal Information” means any information or set of information that identifies or could be used to identify you. Personal Information collected by the Site may include name, address, contact numbers, e-mail address, but may include other information when needed (such as a business-related data).
CHOICE: You may elect not to have your Personal Information either (a) disclosed to an unrelated third party, or (b) used for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. In the event you wish to restrict your Personal Information from any such disclosure or use, please contact us at firstname.lastname@example.org to review your request. You may have an opportunity to elect to receive recurring informational/promotional e-mail from us. Our email correspondence will include instructions on how to update certain Personal Information and how to unsubscribe from our emails. Please follow the instructions in the emails to opt-out of an email. We will unsubscribe you from that newsletter or other programs within thirty business days.
ACCOUNTABILITY FOR ONWARD TRANSFERS TO THIRD PARTIES: ForeSoft is responsible for Personal Information in our possession or custody, including Personal Information that we may transfer to a third party (our Wells Fargo merchant account for credit card processing). In connection with the purposes described in the “Notice” Section above, ForeSoft may transfer your Personal Information to Wells Fargo bank. In cases of onward transfers to Wells Fargo, ForeSoft will limit the Personal Information shared to the minimum amount necessary, and have obtained assurances from them that they will safeguard Personal Information consistent with this Policy.
SECURITY: ForeSoft will take all necessary precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
DATA INTEGRITY: ForeSoft will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. We will take all necessary steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.
ACCESS AND CORRECTION: ForeSoft customers are provided with full access to their Personal Information and business-related data with the ability to correct, amend, or delete their information and data.
VERIFICATION: ForeSoft will use a self-assessment verification approach and conduct compliance audits of its applicable privacy practices to verify adherence to this Policy.
DISPUTE RESOLUTION AND ENFORCEMENT: In compliance with the Privacy Shield Principles, ForeSoft Corporation commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Private Shield policy should first contact ForeSoft Corporation at: email@example.com
ForeSoft Corporation has further committed to refer unresolved Privacy Shield complaints to ICDR/AAA, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit the independent recourse mechanism website: http://info.adr.org/safeharbor for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you.
Any complaints or concerns regarding human resources data transferred from the EU, in the context of the employment relationship between ForeSoft and our employees located in the EU, that cannot be resolved internally will be referred to the applicable EU Data Protection Authorities to address complaints and provide appropriate recourse, which will be provided free of charge to the individual. ForeSoft is committed to following the determination and advice of these authorities. Under certain circumstances, an individual may choose to invoke binding arbitration to resolve any disputes that have not been resolved by other means.
ForeSoft complies with the EU-U.S. Privacy Shield Principles and is subject to the investigatory and enforcement powers of the FTC.
Any employee that ForeSoft 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 ForeSoft to these EU-U.S. Privacy Shield Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet legal, governmental or national security obligations, including requirements to cooperate with law enforcement; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
CONTACT INFORMATION: Questions or comments regarding this Policy should be submitted to ForeSoft’s Privacy Office by mail to:
Attn: Privacy Office
Long Grove, IL 60047
or by e-mail to ForeSoft’s Privacy Office: firstname.lastname@example.org
EU-U.S. PRIVACY SHIELD POLICY EFFECTIVE DATE: December 2016