Last Updated: January 30, 2015
IActionable, Inc. (“IActionable,” “we,” or “us”) has certified compliance with the U.S.-EU and U.S.-Swiss Safe Harbor frameworks for the handling of Personal Information (as defined below) that IActionable receives in the United States from the European Union, Iceland, Liechtenstein, Norway (collectively, “EEA”) or Switzerland. This Safe Harbor Policy describes how we comply with the Safe Harbor privacy principles of notice, choice, onward transfer, access, security, data integrity, and enforcement (the “Safe Harbor Principles”). Our Safe Harbor certification can be found at https://safeharbor.export.gov/list.aspx. For more information about the Safe Harbor Principles, please visit www.export.gov/safeharbor.
For purposes of this Safe Harbor Policy, “Personal Information” means any information or set of information in any format that identifies or could be used by or on behalf of IActionable to identify an individual.
- the purposes for which we collect and use Personal Information;
- the types of third parties to which we disclose Personal Information;
- the choices we offer individuals for limiting our use and disclosure of their Personal Information and how to exercise such choices; and
- how to contact us about our Personal Information practices.
We also have also bound our business customers by contract to comply with applicable foreign laws, which may include the requirement to provide appropriate notice to individuals whose Personal Information such businesses disclose to IActionable.
When we collect Personal Information directly from individuals, we offer each individual the opportunity to choose whether their Personal Information is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by such individual. Individuals may contact IActionable as indicated in the “Contact us” section below regarding our use or disclosure of their Personal Information.
When we receive Personal Information from business customers about individuals in the EEA or Switzerland, we inform such individuals that they may exercise certain privacy rights and choices by contacting the business customer that provided their Personal Information to us.
3. Onward Transfer
We may share Personal Information with our contractors, service providers, and other third parties we use to help up operate our business or administer activities on our behalf. Except as described below, we require such third parties to either (i) certify compliance with the U.S.-EU Safe Harbor and/or the U.S.-Swiss Safe Harbor frameworks to the U.S. Department of Commerce, or (ii) contractually agree to provide at least the same level of protection for Personal Information as is required by the relevant Safe Harbor Principles. These requirements do not apply to third parties that are (a) subject to the European Union Data Protection Directive 95/46/EC or the Swiss Federal Act on Data Protection; (b) located in a country deemed by the European Commission or Swiss FDPIC to adequately safeguard Personal Information (e.g., companies located in Canada); or (c) subject to another data protection adequacy basis.
6. Data Integrity
We take reasonable steps to ensure that Personal Information we obtain is relevant for the purposes for which we use the information, and that such information is reliable, accurate, complete, and current. We depend on our business customers and individuals to update and correct Personal Information to the extent necessary.
We conduct compliance audits of our relevant privacy practices to verify adherence to this Safe Harbor Policy. Any employee who IActionable determines is in violation of this Safe Harbor Policy will be subject to disciplinary action up to and including termination of employment.
8. Dispute Resolution
Users may file a complaint with IActionable regarding our handling of their Personal Information by contacting us as set forth in the “Contact us” section below. We will investigate and attempt to resolve complaints and disputes regarding our use and disclosure of Personal Information through our internal complaint resolution processes. For complaints that cannot be resolved between IActionable and the complainant, IActionable has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles, and to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland.
9. Changes to this Safe Harbor Policy
This Safe Harbor Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on www.iactionable.com for at least 60 days whenever this Safe Harbor Policy is changed in a material way.
12. Contacting us
400 S Mill Pond Drive D5
Lehi, UT 84043