Effective September 29, 2017
DiscoverReady (“We” “Us” or “Our”) does not collect personal information from users of Our website except (1) information provided to Us by your web browser, (2) to the extent you provide Us with personal information in the form of an email or by entering information on Our website, and (3) to the extent you apply for a position with Us through Our website. We will use personal information you provide Us only for the purpose for which it is provided, except We may use information in an aggregate form for purposes of evaluating the success of Our website through traffic analysis.
PRIVACY SHIELD FRAMEWORK
On occasion, DiscoverReady collects personal information regarding individuals in the European Union and Switzerland, including HR information, through services provided to our customers (“Customers”), for which we are the data processor. DiscoverReady collects such information in accordance with applicable privacy laws, regulations, and principles.
Specifically, DiscoverReady complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
- Notice. We will notify you about the purposes for which We handle and use information about you, the types of third parties to which We disclose that information, and the choices and means, if any, We offer individuals for limiting the use and disclosure of their personal information. This Notice covers both Non-Human Resources and Human Resources information.
- Choice. We will give you the opportunity to choose (opt-out) whether your personal information will be disclosed to a third party or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by you. For Human Resources information, We will get your affirmative (opt-in) consent if the information is to be disclosed to a third party or used for a purpose other than its original purpose or a purpose authorized subsequently by you.
- Accountability for Onward Transfer (Transfers to Third Parties). We will apply the Notice and Choice principles if We disclose information to a third party. If We transfer information to a third party that is acting as Our agent, We will require the third party to have adequate privacy protection as is required by the relevant Privacy Shield Principles. With respect to onward transfers, We remain liable under the Principles if Our agent processes personal information in a manner inconsistent with the Principles, unless We prove that We are not responsible for the event giving rise to the damage.
- Security. We take reasonable precautions to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We limit access to your personal information to those personnel who have a specific business purpose for maintaining and processing such information. Individuals who have been granted access to your personal information agree to protect the security, confidentiality and integrity of that information.
- Data Integrity and Purpose Limitation. We will take reasonable steps to ensure that data is reliable for its intended use, and is accurate, complete, and current. We will take precautions to assure the personal information is relevant for the purposes for which it is to be used. In certain situations, We may be required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.
- Access. You may access your personal information that We hold, and you may correct, amend, or delete that information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the privacy risks in question, or where the rights of persons other than you would be violated. To access, correct, or update your personal information, please email us at Privacy@DiscoverReady.com. Please include “My Personal Information under Privacy Shield” in the subject line.
- Recourse. In compliance with the Privacy Shield Principles, DiscoverReady commits to resolve complaints about Our collection or use of your personal information.
- European Union and Swiss individuals with Privacy Shield inquiries or complaints regarding our Privacy Shield policy should first contact Us via e-mail at Privacy@DiscoverReady.com, or in writing to DiscoverReady, 55 Broadway, 6th Floor, New York, NY 10006, Attention Privacy Department.
- For unresolved Privacy Shield complaints regarding non-Human Resources information, DiscoverReady has committed to refer those complaints to the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR/AAA), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact ICDR/AAA at http://info.adr.org/safeharbor for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you.
- With regard to Human Resources data transferred from the EU and Switzerland in the context of the employment relationship, We commit to cooperating with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC), and complying with the advice given by such authorities.
- You may have the ability, under certain conditions, to invoke binding arbitration with a Privacy Shield Panel for complaints regarding Our Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For additional information regarding this arbitration, please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
- Enforcement and Liability. The Federal Trade Commission has jurisdiction over DiscoverReady’s compliance with the Privacy Shield.