|
Privacy Policy for Safe Harbor Compliance
Introduction
docAssist, Incorporated., ("docAssist") is a global SAAS document management provider. Your privacy is important to us. We adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union ("EU") to the United States of America, and we follow the Safe Harbor Principles published by the U.S. Department of Commerce ("Principles") with respect to all such data. If there is any conflict between the policies in this statement and the Principles, the Principles will govern. This statement outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it, and the choices affected individuals have regarding our use of, and their ability to correct, that information.
This statement applies to all personal information we handle (except as noted below), including on-line, off-line, and manually processed data. For purposes of this statement, "personal information" means information that:
is transferred from the EU to the United States
is recorded in any form
is about, or pertains to, a specific individual
can be linked to that individual
It does not include information that pertains to a specific individual, but from which that individual could not reasonably be identified.
Principles Protecting Individuals' Privacy
Notice and Choice
To the extent permitted by the Safe Harbor Agreement, we reserve the right to process personal information in the course of providing services to our clients without the knowledge of individuals involved. Where we collect personal information directly from individuals in the E.U., we inform them about the types of personal information we collect from them, the purposes for which we collect and use it, and the types of non-agent third parties to which we disclose that information. We also inform those individuals about the choices and means, if any, we offer individuals for limiting the use or disclosure of their information.
Disclosures and Transfers
docAssist will not disclose an individual's personal information to third parties, except when one or more of the following conditions is true:
We have the individual's permission to make the disclosure
The disclosure is required by law
The disclosure is reasonably related to the sale or disposition of all or part of our business
The information in question is publicly available
The disclosure is reasonably necessary for the establishment or defense of legal claims
The disclosure is to another docAssist entity or to persons or entities providing services n our or the individual's behalf (each a "transferee"), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question
is subject to law providing an adequate level of privacy protection
has agreed in writing to provide an adequate level of privacy protection
subscribes to the Principles
Permitted transfers of information, either to third parties or within docAssist, include the transfer of data from one jurisdiction to another, including transfers to and from the United States of America. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated.
Data Security
docAssist takes reasonable steps to protect your information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of our clients, docAssist has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we process.
Data Integrity
We process personal information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.
Access and Correction
If an individual becomes aware that information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may contact us using the contact information below. We will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate. The individual will need to provide sufficient identifying information, such as name, address, birth date, and social security number. We may request additional identifying information as a security precaution. In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal information.
Permitted transfers of information, either to third parties or within docAssist, include the transfer of data from one jurisdiction to another, including transfers to and from the United States of America. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated.
Data Security
docAssist takes reasonable steps to protect your information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of our clients, docAssist has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we process.
Data Integrity
We process personal information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.
Access and Correction
If an individual becomes aware that information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may contact us using the contact information below. We will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate. The individual will need to provide sufficient identifying information, such as name, address, birth date, and social security number. We may request additional identifying information as a security precaution. In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal information.
Enforcement and Dispute Resolution
We utilize the self-assessment approach to assure compliance with our privacy statement. We verify that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles. We encourage interested persons to raise any concerns with us using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy. Any person under our control whom we determine is in violation of our privacy policies will be subject to disciplinary process.
Any claim arising out of or relating to our adherence to the EU Data Directive, or the breach thereof, that cannot be resolved through our internal processes, will be settled by arbitration administered by the American Arbitration Association (AAA) in accordance with its applicable commercial rules. Any arbitrator will be either an attorney or retired judge having significant and recognized experience with and knowledge of privacy issues and information technology. The arbitration panel should apply Florida law, without regard to it conflict of laws principles, as well as the Safe Harbor Enforcement Principles issued by the U.S. Department of Commerce htttp://www.export.gov/safeharbor/SHPRINCIPLESFINAL.htm). In addition, the exclusive location for such arbitration will be Pembroke Pines, Florida. All decisions of the arbitration panel will be final and binding on the parties, which waive any right to further appeal the arbitration award, to the extent an appeal may be lawfully waived.
We are also subject to the jurisdiction of the US Federal Trade Commission.
Privacy Statement Changes
This privacy statement may be changed from time to time, consistent with the requirements of the Safe Harbor. We will post any revised policy on our Web site (www.docAssist.com), or a similar Web site that replaces that Web site.
Information Subject to Other Policies
We are committed to following the Principles for all personal information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of the firm that may differ in some respects from the general policies set forth in this statement.
Information relating to present or former docAssist personnel is subject to our policies concerning personnel data privacy, which are available to present docAssist personnel on docAssist's intranet and to former docAssist personnel upon request.
Information obtained from or relating to clients or former clients is further subject to the terms of any privacy notice to the client, any agreements with the client, and applicable laws and professional standards.
How to Contact Us
Questions, comments or complaints about docAssist's Safe Harbor Data Privacy Statement or data collection and processing practices can be e-mailed to info@DocAssist.com, mailed to docAssist, Inc., 701 Promenade Drive Suite 204, Pembroke Pines, FL 33026. In the event that a complaint is not satisfactorily addressed bydocAssist within a reasonable time frame, you may contact the Federal Trade Commission at www.ftc.gov/ftc/complaint.htm, or via telephone at 202-382-4357.
EFFECTIVE DATE: March 10, 2008
|
