Last updated on July, 17, 2020
On July 16, 2020, the Court of Justice for the European Union (EU) issued a significant ruling in a case examining transfers of data from the EU. This ruling invalidated the EU/United States (US) Privacy Shield framework. We understand that some of our customers may have questions about the impact of this ruling. As an Interfolio customer, you can continue to use the Interfolio Software as a Service in compliance with European law. The Court’s ruling does not change your ability to transfer data today between the EU and US.
We have provided customers with overlapping protections under both the Standard Contractual Clauses (SCCs) and Privacy Shield frameworks for data transfers from the EU. Although the July 16 ruling invalidated the use of Privacy Shield moving forward, the SCCs remain valid. Our customers are protected under SCCs and under GDPR. The ruling does not change data flows for our Customers. We will continue to transfer data in compliance with today’s ruling and further guidance from EU data protection authorities.
We routinely work to advance our protections for customers based on developments like these. Interfolio embraced Privacy Shield as a successor to Safe Harbor after that framework was invalidated, and we have extended GDPR rights to our worldwide customer base. Privacy is ever evolving. Our customers can be assured that we are committed to ensuring their data will continue to flow securely through our services in full compliance with all applicable GDPR guidelines and that we’ll work collaboratively with all involved parties as new approaches to EU/US data protection are considered and finalized. If you have any questions, please reach out to us at firstname.lastname@example.org.
Interfolio processes your information for the purposes described in this policy, which include “business purposes” under the CCPA.
- “Visitor”, which means that you simply browse the Site;
- “Applicant” or “Candidate” which means you have registered with us and established an Account. Applicants/Candidates may be students, employees or faculty members of a University or may join Interfolio without such affiliation;
- “Recommender”, which means that you have been asked to submit a letter of recommendation for an Applicant;
- “University User”, which means you are an employee, contractor or agent of a University operating in such capacity. A “University” is a college or university with whom Interfolio has a contractual relationship, generally with the career services department or a specific academic department, to provide services to students, employees and faculty members; and
- “Recipient User”, which means an employee, contractor or agent of a college, university or other employer that uses the Service to locate potential employees and/or faculty members (“Recipient”).
So we are clear about the terminology we are using, when we use the phrase “Personal Information”, we mean contact information (i.e., your name, address, email address, and/or telephone number) and any other non-public information that is used or intended to be used to personally identify an individual, and information associated with the foregoing. When we use the phrase “Anonymous Information”, we mean information that is not associated with or linked to your Personal Information. Anonymous Information does not enable identification of or contact with, individual persons.
How We Collect Information
We receive and store information you voluntarily provide to us (either through the Site or in some other way) upon registration or your use of the Site and Services. When you register with us, regardless of the type of User you are, we require you to provide certain Personal Information, such as your name and email address. You may choose to provide additional Personal Information as part of certain Services. As a rule, Interfolio only collects information necessary to provide the Services you or your institution have requested.
Some of our Services are designed for job Applicants, in which case the following provisions apply. Please remember that you do not have to submit any of this additional information, but we may not be able to provide you certain Services without that information.
- If you are an Applicant creating a dossier on the Site for our document transmission services (a “Dossier”), we enable you to submit information relevant to your Dossier, including your contact information, information about your experience, education, and interests. We will also collect and manage documents associated with your Dossier, such as your writing samples, transcripts, letters of recommendation, and cover letters.
- If you are an Applicant creating your portfolio on the Site to publish on our Site (“Portfolio”), in addition to the information we may collect for your Dossier, we may collect additional information about your work history, publications, experience and other information you voluntarily submit to us, whether through the Site or otherwise.
Disclosure—Information Collected from Third Parties.
Certain Personal Information may be provided about you by other Users. For example, if you are a University User, someone within your University will have registered you and granted you access to our Services. If you are a Recommender, an Applicant may provide us your name and email address. We will consider any Personal Information about you collected as part of the registration process to be your Personal Information.
Disclosure—Usage of Third Party Cookies
How We Use Information
As we mentioned above, we use Personal Information to: (a) assist you in managing the documents in your Dossier and Portfolio, (b) provide you an online location for your academic portfolio (if you so choose); (c) facilitate Applicants applying to Recipients; and (d) otherwise connect Applicants to Recipients. As a result, we use your Personal Information to:
- Administer your Account;
- Provide you with Services and customer support;
- Tailor the features of the Site or Services to you;
- Respond to your requests, resolve disputes and/or troubleshoot problems;
- Communicate with you about the Site and the Services.
We may also use your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you, any other individual and the applicable University or Recipient.
We may send you communications via email about the Site and Services. You can opt out of receiving certain communications from the Site by clicking the “Unsubscribe” link at the bottom of each email. Please note that even if you unsubscribe or opt-out, we may still send you Site and Service related communications (e.g., emails related to your account).
Disclosure of Information
If you are an Applicant, you are probably using our Services to help you either send components of your Dossier to Recipients or to manage your online Portfolio. Either way, our Services operate on the principle of a submission event. Our Services are designed to manage your distribution of certain Personal Information to selected Recipients (or, in some cases, on our Site). As an Applicant, we may (and you hereby authorize us to) disclose the Personal Information selected by you to Recipients designated by you. To be clear, if you tell us to send your Dossier to ABC University, we will consider it an authorization to disclose your Dossier to that university (and you agree that it will constitute an authorization). Additionally, if you maintain a Portfolio, you authorize us to disclose the Personal Information selected by you in the manner designated by you on our Site (whether publicly or privately).
We may disclose certain Personal Information:
- To third parties to whom you ask or authorize us to send Personal Information (including, if applicable, Recipients and/or your University);
In the event we offer public or private forums on the Site or Services, you are welcome to share as much Personal Information as you think is necessary and appropriate (or authorize us to share such information). But please be aware than any Personal Information will be made available to other Registered Users and/or generally on our Site and we do not control what third parties do with such information.
Disclosure to Universities or Recipients
Giving you tools to help you protect your Personal Information is a vital part of our mission. It is up to you to make sure you are comfortable with the information you provide. We do provide Personal Information to Recipients to whom you have authorized disclosure and, if applicable, your University. We do not control how Universities or Recipients (or their respective Users) use or disclose the information they obtain from us.
If you are affiliated with a University, you hereby authorize us, and we may disclose your Dossier, related Personal Information and your Dossier’s delivery history to your University and its University Users, unless you opt-out of such disclosure in your account settings. If you do not wish to share this information with your University, you can opt-out by logging into your account and changing your privacy settings.
IF YOU AUTHORIZE US TO SHARE PERSONAL INFORMATION WITH A RECIPIENT OR YOUR UNIVERSITY, WE DO NOT HAVE ANY CONTROL OVER HOW ANY SUCH RECIPIENT OR UNIVERSITY USES AND DISCLOSES YOUR PERSONAL INFORMATION, INCLUDING INFORMATION YOU PROVIDE DIRECTLY TO THAT RECIPIENT. YOU ACKNOWLEDGE AND AGREE THAT (1) INTERFOLIO DOES NOT EVALUATE ANY RECIPIENT’S OR UNIVERSITY’S PRIVACY PRACTICES, AND (2) INTERFOLIO WILL NOT HAVE ANY LIABILITY FOR ANY ACTIONS OF ANY RECIPIENT OR UNIVERSITY. YOU SHOULD KNOW THAT RECIPIENTS TO WHOM WE MAY DISCLOSE YOUR DISCLOSED PROFILE MAY SHARE YOUR DISCLOSED PROFILE WITH OTHERS.
Accountability for Onward Transfer – EU-U.S. Privacy Shield Principles
As described in the Privacy Shield Principles, Interfolio is accountable for personal data that it receives under the Privacy Shield Framework and subsequently transfers to third parties. If third parties that process personal data on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.
Accessing and Controlling your Information
We acknowledge the individual’s right to access their personal data. To change information that you have previously provided Interfolio, you may log in to your account at https://www.interfolio.com and edit the information on your Settings page. You may also contact Interfolio’s Customer Support to change this information by emailing email@example.com or by calling (877) 997-8807. If you change and/or request changes to your information, subsequent uses or disclosures of that information by us will reflect those changes, however, we do not have the ability to update any information previously disclosed to any third party, including your University. We will correct any inaccuracies in any Personal Information that we have in our possession once notified of the requested change. We endeavor to process these requested changes as soon as is possible, but it may take up to thirty (30) days to make requested changes.
You may not be able to access Confidential Personal Information submitted to the Services about you (e.g. a confidential letter of recommendation). Similarly, if you have provided us with Confidential Personal Information, you may not be able to control this information or to whom it is disclosed. However, you can request its deletion by emailing firstname.lastname@example.org or by calling (877) 997-8807. Such a request will not affect any previously disclosed information.
Certain information is necessary in order for us to provide the Site or Services; therefore, if you delete such necessary information you will not be able to use the Site or Services. If you wish to have your Personal Information removed from our databases or to discontinue the Service you may contact us at email@example.com. Within a reasonable time period after we receive your request—and it may take up to thirty (30) days to process the deletion—we will remove your Personal Information provided, however, that we may continue to maintain and use your Personal Information in a manner where the information is no longer personally identifiable.
Please note that even though you may request the deletion of your Personal Information by us, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, troubleshoot problems, or enforce our Services Agreement) to keep this information and not delete it (or to keep this information for a certain time) in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete Personal Information, it will be deleted from the active database, but may remain in our archives.
Third Party Sites
You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
The security of your personal information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can send email us at firstname.lastname@example.org. This site has security measures in place to protect the loss, misuse and alteration of the information under our control.
Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and explain why.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
Social Media Widgets
The Site is not directed to children and children are not eligible to use our Services. Protecting the privacy of children is very important to us. We do not collect or maintain Personal Information from people we actually know are under 13 years old, and no part of the Site or Services is designed to attract people under 13 years old. If we later obtain actual knowledge that a User is under 13 years old, we will take steps to remove that User’s Personal Information from our records.
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