For over 22 years, respecting and protecting our clients’ confidential data and privacy has been vital to our business. By sharing our Confidentiality Statement, we trust that our clients will better understand how we keep client information confidential while using it to provide services and products. Other privacy requirements or policies may apply to individual Compass Consulting clients, as required.
Privacy & Confidentiality Statement
Employees may, during the course of his/her services hereunder, have access to, and acquire knowledge from, material, data, systems and other information of or with respect to Compass Consulting or any of its Clients which may not be accessible or known to the general public. Any knowledge acquired by the Employee from such material, data, systems or information or otherwise through its engagement hereunder shall not be used, published or divulged by Employee in connection with any services rendered by Employee to any other person, firm or corporation, or in any other manner or connection whatsoever. The provisions of this paragraph shall survive the termination of this Agreement.
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Compass Information Technology, Inc. Safe Harbor Policy
Affirmative Statement
Compass Information Technology, Inc. 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. Compass Information Technology, Inc. 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 Compass Consulting’s certification, please visit http://www.export.gov/safeharbor/
Introduction
Compass Information Technology, Inc. (the “Company”) is a leading technology services provider that offers cloud-based solutions and managed services that help companies achieve their important business goals. Protecting consumer privacy is important to the Company. The Company and its affiliated United States subsidiaries (hereinafter collectively referred to as the “Company,” “we,” “us” or “our”) adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union (“EU”) to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern. This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by the Company whether in electronic, paper or verbal format.
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“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
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Principles
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Notice
Company shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which the Company discloses or may disclose that Information. Company shall provide the individual with the choice and means 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 the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which it was originally collected.
Choice
The Company will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) 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, the Company will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Company shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.
Onward Transfers
Prior to disclosing Personal Information to a third party, Company shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Company shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.
Data Security
Company shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Company cannot guarantee the security of Information on or transmitted via the Internet.
Data Integrity
Company shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Company shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.
Access
Company shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
Enforcement
Company uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.
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The Company has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the BBB EU SAFE HARBOR web site at https://www.bbb.org/en/us for more information and to file a complaint.
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Amendments
This privacy policy may be amended from time to time consistent with the requirements of the EU-U.S. Privacy Shield Framework. We will post any revised policy on this website.
Information Subject to Other Policies
The Company is committed to following the Principles for all Personal Information within the scope of the EU-U.S. Privacy Shield Framework. However, certain information is subject to policies of the Company that may differ in some respects from the general policies set forth in this privacy policy.
Contact Information
Questions, comments or complaints regarding the Company’s EU-U.S. Privacy Shield policy or data collection and processing practices can be mailed or emailed to:
Compass Information Technology, Inc.
Attn: Legal Department
5235 Mission Oaks Blvd., #344
Camarillo, CA 93012
Email: info@compassconsult.com
Effective date: May 1, 2018
