EU – US / UK/Swiss – Data Privacy Framework
Effective Date: August 1, 2023
In compliance with the Data Privacy Framework, Cimplifi commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Framework. European Union, United Kingdom, and Swiss individuals with Data Privacy Frameworkinquiries or complaints should first contact Marla Crawford by email at [email protected]
Cimplifi has further committed to refer unresolved privacy complaints under the Data Privacy Framework to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
If your Data Privacy Framework complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Business Purposes for the Collection and Use of Personal Data
Cimplifi provides various solutions to its employees and clients. Cimplifi collects Personal Data from Individual Clients and employees when they register with us, log-in to their account, complete surveys, request information, purchase products or become employee.
The Personal Data that we collect may vary based on the Individual Client or Employee interaction with our website and request for our services. As a general matter, Cimplifi collects the following types of Personal Data from its Individual Clients and Employees: contact information, including, a contact person’s name, email address, mailing address, telephone number, title, tax information, identification / work authorization and company name, as well as payment information (which may contain bank account information). Individual clients and employees have the option to log into their accounts online and to request service online or through electronic mail and phone. We will collect information that they choose to provide to us through these portals.
When Individual Clients and Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.
The information that we collect from Individual Employees and Clients is used for the purposes of hiring & payment or the implementation & billing of purchased services. These services may include payment, reporting, invoicing, and other operations related to providing services and products to the Individual Employee and Client.
For certain products, Cimplifi serves as a service provider. In our capacity as a service provider, we will receive, store, and/or process Personal Data. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of our Clients and/or agents. The information that we collect from our Clients in this capacity is used for eDiscovery investigations and other operations related to providing services to the Individual Client, and as otherwise requested by our Client and/or agent.
Cimplifi uses Personal Data that it collects directly from its Individual Clients and indirectly in its role as a service provider for the following business purposes, without limitation: maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including eDiscovery investigations and other operations related to providing services to an Individual Client); satisfying governmental reporting, tax, and other requirements (e.g., import/export); storing and processing data, including Personal Data, in computer databases and servers located in the United States; verifying identity (e.g., for online access to accounts); as requested by the Individual Client; for other business-related purposes permitted or required under applicable local law and regulation; and as otherwise required by law.
Disclosures / Onward transfers of Personal Data
Cimplifi’s accountability for personal data that it receives in the United States under the Data Privacy Framework and subsequently transfers to a third party is described in the Data Privacy Framework. In particular, Cimplifi remains responsible and liable under the Data Privacy Framework if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Framework, unless Cimplifi proves that it is not responsible for the event giving rise to the damage.
Cimplifi may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by Cimplifi and they must agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy.
Accessing Personal Data
Cimplifi personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
Right to Access, Change or Delete
Individual Clients and Employees have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which Cimplifi collected it. Individual Clients and Employees may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and Cimplifi policies. Upon reasonable request and as required by the Privacy Shield principles, Cimplifi allows Individual Clients and Employees access to their Personal Data, in order to correct or amend such data where inaccurate.
Individual Clients and Employees may edit their Personal Data by logging into their account profile or by contacting Cimplifi by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to local Cimplifi office.
Cimplifi will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject.
Cimplifi will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected]
Cimplifi is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Cimplifi does not endorse, nor does it participate in the practice of “spamming” (sending of unsolicited promotional e-mail). If you believe you have received such a message, contact [email protected]. Cimplifi also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
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