Interfolio EU-U.S. and Swiss-U.S. Privacy Shield Notice

Effective: January 1, 2020

Interfolio, Inc. (“We” or “Our”) has certified with the EU-U.S. and Swiss-U.S. Privacy Shield with respect to the personal data we receive and process on behalf of our customers through our online platform (the “Services”). Interfolio certifies that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement for personal data submitted by our customers in the European Union, the United Kingdom and Switzerland through the Services, and our Privacy Shield certification will be available here.  We may also process personal data our customers submit relating to individuals in the EU via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.

Data Processed

We provide the Services so that our customers can manage their faculty administrative processes. In providing these Services, we process messages, files and other content our customers submit to the Services or instruct us to process on their behalves in connection with the Services (“Customer Data”). As set forth in our privacy policy, Interfolio also collects other information (“Other Information”) that may include personal data, such as usage information and cookie information.

Purposes of Data Processing

We process Customer Data in accordance with Customer’s instructions, including any applicable terms in a customer’s agreement with Customer and Customer’s use of Services functionality, and as required by applicable law. Interfolio is a processor of Customer Data and Customer is the controller. To fulfill these purposes, we may, for example, access Customer Data to provide the Services, to prevent or address service or technical problems, to respond to customer support matters, to follow the instructions of our customer who submitted the data, or in response to contractual requirements with our customers. As set forth in our privacy policy, Interfolio uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business.

Third Parties With Whom We May Share Data

We use a limited number of third-party providers to assist us in providing the Services to our customers and to support our customers and our business. As of the date hereof, these third-party providers perform technical operations, such as database monitoring, data storage and hosting services, and help us provide customer support and other business functions. These third parties may access, process or store personal data in the course of providing these services, but based on our instructions only.

If we receive personal data subject to our certification under the Privacy Shield and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the personal data in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.

Questions or Complaints:

If you are a resident of a European country participating in the Privacy Shield and you believe we maintain your personal data within the scope of this Privacy Shield certification, you may direct any questions or complaints concerning our Privacy Shield compliance to privacy@Interfolio.com or at our mailing address:

Interfolio Inc.
1400 K Street, NW, 11^th Floor
Washington, DC  20005
United States

We will work with you to resolve your issue.

Dispute Resolution

If you are a resident of a European country participating in the Privacy Shield and you have not received timely response to your concern, or we have not addressed your concern to your satisfaction, you may seek further assistance, at no cost to you, from BBB, which is an independent dispute resolution body in the United States.

We also commit to cooperate with competent EU, Swiss and UK data protection authorities with regard to our customers end users’ human resources data transferred from a European country participating in the Privacy Shield in the context of the employment relationship.

Arbitration

You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of a European country participating in the Privacy Shield must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from BBB; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.

U.S. Federal Trade Commission Enforcement

Our Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Right of Access

Some international users (including those whose personal data is within the scope of this Privacy Shield certification) have certain legal rights to access certain personal data we hold about them and to obtain its correction, amendment or deletion. Those users may exercise some of those rights through the options described in our Privacy Policy.  Please be advised that because our personnel have a limited ability to identify and access an individual user’s personal data that a customer has submitted to the Services, if you wish to request access, to limit use, or to limit disclosure, we may first refer your request to the customer who submitted your personal data, and we will support them as needed in responding to your request.

Requirement to Disclose

We may disclose personal data when we have a good faith belief that such action is necessary to: conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; or to enforce our contractual obligations.