The United States Department of Commerce and the European Commission have agreed on a set of data protection principles (the “Safe Harbor Principles”) to enable U.S. companies to satisfy the EU law requirement that personal information transferred from the EU to the United States be adequately protected.
Vericlaim adheres to the Safe Harbor Principles.
This Policy applies to all personal information received by Vericlaim in the United States from the EU, in any format including electronic, paper or verbal.
For the purposes of this policy the following definitions shall apply:
“Agent” means any third party that uses personal information provided to Vericlaim to perform tasks on behalf of and under the instructions of Vericlaim.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of Vericlaim to identify an individual. Personal information does not include information that is encoded, anonymized, aggregated 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, Vericlaim 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 are based on the Safe Harbor Principles.
NOTICE and CONSENT
We will collect and process data fairly and lawfully, and where appropriate, with the knowledge or consent of the data subject. The type of notice or consent required will depend on the context and the circumstances, the sensitivity of the Personal data, the data subject’s reasonable expectations, and legal requirements. Vericlaim has informed its Affiliates based in the EU that they may be responsible for providing appropriate notice to data subjects whose Personal Data are transferred to the Unites States.
We will collect and process Personal Data only for specified, limited, and legitimate purpose.
We will not process Personal Data in a manner inconsistent with the purposes for which it was originally collected without first obtaining the data subject’s consent. The type of consent required will depend on the context and the circumstances, the sensitivity of the Personal Data, the data subject’s reasonable expectations, and legal requirements. Vericlaim has informed its Affiliates based in the EU that they may be responsible for providing data subjects with a choice as to whether their personal data may be used for a purpose that is inconsistent with the purpose for which the information was originally collected or subsequently authorized by the individual.
Vericlaim will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Vericlaim will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS
Vericlaim will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. If Vericlaim has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Vericlaim will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION
Upon request, Vericlaim will grant individuals reasonable access to personal information that it holds about them, and Vericlaim will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
Vericlaim will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
We will periodically verify compliance with privacy and data protection laws, this policy, and related procedures.
Any questions or concerns regarding the use or disclosure of personal information should be directed to the Vericlaim Corporate Office at the address given below. Vericlaim 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. If the complaint cannot be resolved through these processes, the data subject may submit the complaint to firstname.lastname@example.org
To learn more about the Safe Harbor program, and to view Vericlaim, Inc.’s certification, please visit http://www.export.gov/safeharbor/.
Questions or comments regarding this Policy should be submitted to the Vericlaim Office by mail or e-mail as follows:
1833 Center Point Circle
Naperville, IL 60563
Attn: Data Protection Department