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.
Purposes of Data Processing
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:
1400 K Street, NW, 11th Floor
Washington, DC 20005
We will work with you to resolve your issue.
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.
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
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.