This notice was updated on October 11th, 2019.
Compensation Tool has subscribed to the Privacy Shield program, which covers both the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and, therefore, Compensation Tool has certified that it adheres to the EU-U.S. Privacy Shield Principles and the Swiss-U.S. Privacy Shield Principles, both of which include Supplemental Principles (collectively, the “EU-U.S. and Swiss-U.S. Privacy Shield Principles”) for Personal Information covered by the Policy. More information about the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, including the list of certified organizations, can be found at www.privacyshield.gov. This Policy applies to Compensation Tool. If there is any conflict between the terms in this Policy and the EU-U.S. and Swiss-U.S. Privacy Shield Principles, the EU-U.S. and Swiss-U.S. Privacy Shield Principles will govern.
Personal Information that is transferred to Compensation Tool from the EEA and Switzerland falls into two categories:
1) Personal Information regarding personnel from Compensation Tool’s visitors, such as name, email address, job title, company and telephone number; and
2) Personal Information from customers’ in connection with the subscription based services provided by the Compensation Tool, which may include information such as name, job title, and compensation related information. In the case of the latter category, Compensation Tool acts as a data processor and processes such information only under the instructions of its customers and with the legal basis for fulfilling a contractual obligation. This information is controlled by Compensation Tool’s customers in the EEA and Switzerland.
Because the requirements of the Privacy Shield program vary depending on whether Compensation Tool is acting as a processor on behalf of its customers or as a data controller, meaning that Compensation Tool makes independent decisions about how that information will be used, Compensation Tool’s policies and practices are described separately below.
COMPENSATION TOOL ACTING AS A DATA PROCESSOR ON BEHALF OF ITS CUSTOMERS
When Compensation Tool acts as a processor on behalf of its customers, the following policies apply to all data processing operations concerning Personal Information that has been transferred from the EEA and Switzerland to the United States.
Use of Personal Information
Compensation Tool will process the Personal Information only for the purposes requested by the customer.
Access and Correction
Compensation Tool will assist the controller (the customer) in responding to individuals exercising their rights under the Principles.
Exclusive Use and No Resale to Third Parties
Compensation Tool will not disclose or otherwise provide Personal data to third parties unless required by law or to protect Compensation Tool, investigate fraud, court order, or other legal process or where required by the customer.
Notice & Choice
Because the Personal Information is under the control of Compensation Tool’s customers, appropriate notice and choice to the individual are provided by Compensation Tool’s customers. As the data processor, Compensation Tool does not have a direct relationship with the customers’ end users.
COMPENSATION TOOL ACTING AS A DATA CONTROLLER
Compensation Tool may receive Personal Information from customers in the EEA and Switzerland.
Use of Personal Information
Any Personal Information sent to us may be used by Compensation Tool and its agents for the following purposes: communications, fulfilling transactions, analytics, and marketing. If we intend to use your information for a purpose that is materially different from these purposes or if we intend to disclose it to a third party not previously identified, we will notify you and offer you the opportunity to opt out of such uses and/or disclosures where it involves non-sensitive information or opt-in where sensitive information is involved.
Compensation Tool gathers certain information about a visitor's visit, access, and use of the Websites and/or Service and stores such information in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and click stream data. Compensation Tol may use this information which does not identify individual users, to analyze trends, to administer the Websites and the Service, to track visitors' movements around the Websites and the Service and to gather demographic information about our visitor base as a whole.
The Compensation Tool is intended for us by adults and are not intended for or targeted at children under 13 years of age. Compensation Tool does not knowingly or intentionally collect information or data on children under 13 years of age. Please contact Compensation Tool at email@example.com if you believe that Compensation Tool has information about a child under 13 years of age.
DISCLOSURES TO AGENTS AND SERVICE PROVIDERS
We sometimes contract with other companies and individuals to perform functions or services on our behalf such as website hosting, data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other services. They may have access to Personal Information needed to perform their functions but are restricted from using the Personal Information for purposes other than providing services for us or to us. Compensation Tool requires that its agents and service providers that have access to Personal Information received from the EEA and Switzerland provide the same level of protection as required by the EU-U.S. and Swiss-U.S. Privacy Shield Principles.
We are responsible for ensuring that our agents, service providers and other third parties to whom we disclose your Personal Information process the information in a manner consistent with our obligations under the EU-U.S. and Swiss-U.S. Privacy Shield Principles.
Compensation Tool uses reasonable physical, administrative and technical safeguards to help protect the Information from unauthorized access, use and disclosure. Compensation Tool also requires that its suppliers protect such information from unauthorized access, use, and disclosure.
All information in the Compensation Tool remains protected via access controls to ensure that it is not improperly disclosed, modified, deleted, or rendered unavailable. Access control procedures ensure access to information is based on the need to know.
All personal data is treated as confidential and is not made available except to members of the Compensation Tool or contractors and vendors where necessary for the provision of Services provided by the Compensation Tool. Access to this information is based on the need to know. The Compensation Tool may conduct periodic audits of the Personal data stored the software and reserves the right to remove any information not necessary for the Compensation Tool services.
The Compensation Tool may conduct periodic Company Information and reserves the right to remove any Company Information not necessary for the Compensation Tool services.
Compensation Tool utilizes an Extended Validation Secure Socket Layer (EV-SSL) which offer the highest degree of authentication and SSL protection. The EV-SSL protocols secure network traffic from eavesdropping, active tampering, or forgery of messages.
DATA INTEGRITY AND PURPOSE LIMITATION
We limit the collection and use of Personal Information to the information that is relevant for the purposes of processing and will not process Personal Information in a way that is incompatible with the purposes for which the information has been collected or subsequently authorized by you. We take reasonable steps to ensure the personal information is reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the Personal Information.
ACCESS TO PERSONAL DATA
Unless providing reasonable access to Personal data creates an unreasonable conflict with the Compensation Tool’s Security Policy, Compensation Tool will provide visitors with reasonable access to Personal data, including in some cases employee information, as well as the ability to review and correct such information.
Visitors wishing to access, amend, correct, remove, or limit use of your information, contact us at firstname.lastname@example.org. Visitors can unsubscribe from or opt out of communications from Compensation Tool by contacting Compensation Tool at email@example.com .
Compensation Tool will take reasonable steps to verify the requestor’s identity before granting access to any Personal data and may limit or deny access to any information where providing such access would be unreasonable, burdensome, or expensive in the circumstances, as determined by Compensation Tool.
ENFORCEMENT AND DISPUTE RESOLUTION
If you have any questions or concerns, please write to us at the address listed below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles.
In the event we are unable to resolve your complaints or disputes, you may contact JAMS (www.jamsadr.com/eu-us-privacy-shield), an alternative dispute resolution provider located in the United States, for more information or to file a complaint. JAMS will investigate and assist you free of charge in resolving your complaint.
As further explained in the EU-U.S. and Swiss-U.S. Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. Compensation Tool US is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
DISCLOSURES REQUIRED BY LAW
Compensation Tool may disclose Information if and when required by law or in the good faith belief that such action is necessary in order to conform to the edicts of the law, comply with legal mandates, enforce its rights, enforce any agreement between Compensation Tool and its customers or to protect the rights, property, or personal safety of Compensation Tool, its employees and agents, its users, and the public.
Compensation Tool, Inc.
1823 Terry Ave Ste 701, Seattle, WA 98101