Privacy Policy

SAFE HARBOR PRIVACY POLICY FOR CONSUMER DATA

iCertainty 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 iCertainty follows with respect to personal consumer information transferred from the European Economic Area (“EEA”) (which currently includes the twenty-eight member states of the European Union (“EU”) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.

iCertainty 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. iCertainty 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, and to view iCertainty’s certification, 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, iCertainty 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 iCertainty in the United States from the EEA 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, and solely for, iCertainty or to which iCertainty discloses personal information for use on iCertainty's behalf.

"iCertainty" means IDocuments, LLC d/b/a iCertainty, its successors, subsidiaries, divisions and groups in the United States.

"Personal information" means any information or set of information that identifies or is used by or on behalf of iCertainty 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, iCertainty 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.

NOTICE: Where iCertainty collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them and the choices and means, if any, iCertainty offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to iCertainty, or as soon as practicable thereafter, and in any event before iCertainty uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a non-agent third party.

Where iCertainty 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.

CHOICE: For personal information, iCertainty will offer individuals 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 individual.

For sensitive personal information, iCertainty will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

iCertainty will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: iCertainty will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. iCertainty will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. We 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 the request.

TRANSFERS TO AGENTS: iCertainty 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, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where iCertainty has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, iCertainty will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, iCertainty will grant individuals reasonable access to personal information that it holds about them. In addition, iCertainty 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 completing our customer service form at www.iCertainty.com/contact or by calling iCertainty’s Headquarters office at (001) 443-452-1950.

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

ENFORCEMENT: iCertainty will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that iCertainty 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 the iCertainty General Counsel at the address given below. iCertainty 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 iCertainty and the complainant, iCertainty has agreed to participate in the dispute resolution procedures of the American Arbitration Association pursuant to the Safe Harbor Principles.

LIMITATIONS ON APPLICATION OF PRINCIPLES
Adherence by iCertainty 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; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

INTERNET PRIVACY
iCertainty sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers. iCertainty 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. ICertainty’s Internet Privacy Policy can be found below.

CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to the iCertainty General Counsel by mail as follows:

iCertainty
General Counsel
1301 Warner Street
Baltimore, Maryland 21230
U.S.A.

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 iCertainty web page (www.iCertainty.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.

EFFECTIVE DATE

July 4, 2015

Additional Privacy Provisions

What we collect

Subject to and in accordance with the Safe Harbor provisions set forth above, we may request and collect the following information:

Name
Organization & title
Contact information (mailing address, email address, phone number)
Demographic information (age, gender, etc.)
Personal preferences

What we do with the information we gather

By gathering this information we can better understand your needs pertaining to our products and services. iCertainty may use this information for the following:

Improve our products and services
Sending promotional emails or direct mail about new products, special offers
Contacting for market research
Customizing our website
Providing to our third party partners for their marketing or promotional purposes

Security

Keeping your information secure is a top priority. In order to prevent unauthorized access or disclosure we have put in place electronic, physical and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

A cookie is a small file that asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or notifies you when visiting a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page use and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer; however, this may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to enable you to visit other websites of interest. However, once you have used these links to leave our site, we do not have any control over other websites. Therefore, we cannot be responsible for the protection and privacy of any information that you provide when visiting such sites. Consequently, such sites are not governed by the iCertainty Privacy Policy. You should exercise caution and examine the privacy statement applicable to the website in question.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

Whenever you are asked to fill in a form on the website, look for the box that you can “click” to indicate that you do not want the information to be used for direct marketing purposes
If you have previously agreed to use of your personal information for direct marketing purposes and no longer care to have your information used, please notify us by emailing to www.iCertainty.com/contact.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required to do so by law.

If you believe any information we are holding is incorrect or incomplete, please email us at the above address.