PRIVACY POLICY
I. SCOPE
EDGAGEMENT provides services to businesses.
This Policy applies to the processing of Individual Personal Data that EDGAGEMENT receives on behalf of our clients and or that we collect as a result of a business transaction as defined by a scope of work with our clients.
This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
II. RESPONSIBILITIES AND MANAGEMENT
EDGAGEMENT has designated its Executive Team to oversee its information security program. EDGAGEMENT’s Executive Team shall review and approve any material changes to this information security program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to [email protected]. EDGAGEMENT will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. EDGAGEMENT personnel will receive training, as applicable, to effectively implement this Policy.
III. COLLECTION AND USE OF PERSONAL DATA
EDGAGEMENT collects Personal Data directly from Individuals when they register with one of our websites, login to their account, participate in reward and recognition programs, participate in meetings, events, and travel programs, redeem award points for individual travel or merchandise, request information, or otherwise communicate with us. EDGAGEMENT also receives Individual Personal Data indirectly from its business customers (Data Controllers) in its role as a service provider (Data Processor).
The Personal Data that we collect may vary based on the Individual’s interaction with one or more of our websites used to provide the services as agreed under contract with our business customers. In general, EDGAGEMENT collects the following types of Personal Data either directly from Individuals, or indirectly from EDGAGEMENT business customers: contact information, including, a contact person’s name, work email address, work mailing address, delivery address for merchandise award delivery, work telephone number, title, and company name. Individuals have the option to log into their accounts online and request assistance via an online form or through a live support option such as chat or telephone, collectively “Portals”. In such cases, we will collect information that they choose to provide to us through these Portals.
When Individuals use our services online, we will collect their IP address and browser type. The information that we collect from Individuals is used for providing services, managing transactions, reporting, other operations related to providing services and products to the Individual and/or to EDGAGEMENT customers in accordance with their contracts.
EDGAGEMENT acts as a service provider to our customers. 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 Data on behalf of, and under the direction of our customers (Data Controllers). The Personal Data that we collect from Individuals in this capacity is used to provide services to the Individual as requested by the Data Controller.
EDGAGEMENT uses Personal Data that it collects directly from Individuals, or indirectly from our customers in our role as a service provider for the following business purposes, without limitation:
- delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing transactions, reporting, and other operations related to providing services to our customers and Individuals);
- 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; for other business-related purposes permitted or required under applicable local law and regulation, and as otherwise required by law.
EDGAGEMENT does not disclose Personal Data to third parties for purposes that are materially different than as specified as the original purpose. Should this change in the future, we will provide affected individuals with the option to opt-out.
IV. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
EDGAGEMENT discloses relevant Personal Data only to a Third Party who reasonably needs to know such Personal Data, and only under a contract with the Third Party that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by the Individual and for no other purpose.
EDGAGEMENT may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, EDGAGEMENT may store such Personal Data in facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by EDGAGEMENT.
V. SENSITIVE DATA
In general, EDGAGEMENT does not receive or collect Sensitive Data from Individuals. Within specific services provided by EDGAGEMENT, and as contractually required and directed by an EDGAGEMENT customer, some sensitive data may be required. In such cases, Individuals will be provided with information to explain why that data is required.
VI. DATA INTEGRITY AND SECURITY
EDGAGEMENT uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. EDGAGEMENT has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. EDGAGEMENT also employs access restrictions, limiting the scope of employees who have access to Personal Data. Further, EDGAGEMENT uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.
VII. ACCESSING PERSONAL DATA
EDGAGEMENT personnel may access and use Personal Data only if they are authorized to do so, only for the purpose for which they are authorized and limited only to Personal Data relevant to the purpose of processing.
IX. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
Right to Access. Individuals 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 EDGAGEMENT collected it. Individuals may review their own Personal Data stored in the databases and request to have it corrected, erased, or blocked, as permitted by applicable law and EDGAGEMENT policies. Upon reasonable request, EDGAGEMENT allows Individuals access to their Personal Data, in order to correct or amend such data where inaccurate. Individuals may edit their Personal Data by logging into their account profile or by contacting EDGAGEMENT by email or other means provided by the website. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individuals should submit a written request via email to [email protected].
Requests for Personal Data. EDGAGEMENT 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.
Satisfying Requests for Access, Modifications, and Corrections. EDGAGEMENT will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
X. CHANGES TO THIS POLICY
This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees aware of changes to this policy either by posting to our intranet, through email, or other means. We will notify affected Individuals if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
XI. QUESTIONS OR COMPLAINTS
EU and Swiss Individuals may contact EDGAGEMENT with questions or complaints concerning this Policy at the following email address: [email protected].
XII. ENFORCEMENT AND DISPUTE RESOLUTION
EDGAGEMENT commits to investigate and resolve complaints about your privacy and our collection or use of your personal information at no cost to the Individual. EU and Swiss individuals with questions or concerns about the use of their Personal Data should contact us at: [email protected]. Individuals may bring a complaint directly to EDGAGEMENT, and EDGAGEMENT will respond to the complaint within 45 days.