Effective Date: September 2, 2016
hc1.com Inc. adheres to the principles of the EU-U.S. Privacy Shield framework with respect to personal data submitted by hc1.com’s customers in reliance on the Privacy Shield. Specifically, hc1.com complies with the E.U.-U.S. Privacy Shield framework as agreed to between the U.S. Department of Commerce and the European Commission regarding the collection, use, and retention of personal information from European Union (EU) member countries. hc1.com has certified that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement, and liability. By participating in the Privacy Shield, we have agreed to abide by the investigatory and enforcement powers of the U.S. Federal Trade Commission or any other U.S. authorized statutory body. For more information on the EU–U.S. Privacy Shield, and to view hc1.com’s certification, please visit the U.S. Department of Commerce’s Privacy Shield website at www.privacyshield.gov.
This notice outlines our general policy and practices for implementing the Privacy Shield Principles. If there is any conflict between the policies in this notice and the Privacy Shield Principles, the Privacy Shield Principles will govern. For the purposes of this notice, “personal data” refers to any personally identifiable information that we receive in the U.S. from the E.U. “Sensitive personal data” is a subcategory of “personal data” and is defined as personal data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or the sex life of the individual.
hc1.com is a data processor on behalf of its Customers. We provide services to our Customers to use to operate aspects of their businesses. hc1.com may process Data our Customers submit to our Services or instruct us to process the Data on their behalves. hc1.com’s Customers are data controllers and decide what Data to submit.
Types of Personal Data Collected and Purposes for Using and Disclosing Personal Data
To provide Services to our Customers, hc1.com collects personal data that includes, but is not limited to, (1) first and last names; (2) email addresses; (3) telephone numbers; (4) mailing addresses; and (5) medical information, such as laboratory test results, generated by our Customers’ clients. “Sensitive data” is a subset of “personal data” and includes information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or the sex life of the individual.
hc1.com processes Data submitted by Customers for various purposes, including, but not limited to: (1) providing hc1.com’s online Services to our Customers and (2) marketing our products and services to our Customers. To fulfill these purposes, hc1.com may access the Data to provide the Services, to correct and address technical or service problems, to follow the instructions of the Customer who submitted the Data, or to fulfill contractual requirements. Please be aware that in rare situations, it may be necessary disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Choice to Limit Use and Disclosure of Personal Data
We recognize that EU individuals have the right to limit the use and disclosure of their personal data, and hc1.com is committed to respecting those rights. We offer individuals the opportunity to opt-out of disclosures of personal data to a third party or the use of personal data for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individual.
We will comply with the Privacy Shield Principles with respect to disclosures of sensitive data including, when applicable, obtaining the explicit consent (i.e., opt-in consent by way of our Customers) of the individual prior to disclosing sensitive data to a third party or using sensitive data for purposes other than those for which it was originally collected or subsequently authorized by the individual.
Accountability for Onward Transfers of Personal Data to Third Parties
We are potentially liable in cases of onward transfers of personal information to third parties, such as when third parties that act as agents on our behalf process personal information in a manner inconsistent with the Privacy Shield Principles. hc1.com uses a limited number of third-party service providers to assist us in providing our Services to Customers. These third parties may access, process, or store personal data in the course of providing their services. hc1.com maintains contracts with these third parties to ensure that they provide the same level of privacy protection as is required by the Privacy Shield principles and to restrict their access, use and disclosure of personal data in compliance with our Privacy Shield obligations.
We also transfer personal data to our third party agents, such as: infrastructure as a service providers and vulnerability testing providers.
Right to Access Personal Data
hc1.com recognizes that EU individuals have the right to access personal data about them, and to limit use and disclosure of their personal data and hc1.com is committed to respect this right. Individuals also have the right to obtain our confirmation of whether we maintain personal data relating to you. Further, hc1.com will also enable you to correct, amend or delete personal data related to you in our possession and control that is inaccurate or incomplete. Your right to access your personal data may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated by the provision of such access. If hc1.com determines that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.
Because hc1.com personnel have limited ability to access the data our Customers submit to our Services, individuals who wish to request access, to limit use, or to limit disclosure of his/her Data must provide the name of the hc1.com Customer who submitted his or her Data to the Service(s). hc1.com will contact the Customer with your request and will support the Customer as needed in responding to your request. To request to access, correct, amend, or delete personal data, please contact hc1.com at firstname.lastname@example.org.
Recourse, Enforcement, and Liability
hc1.com has further committed to refer unresolved Privacy Shield complaints to 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 addressed your complaint to your satisfaction, please contact or visit www.adr.org for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you.
Please note that if an individual’s complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.