EU-US Privacy Shield Privacy Policy

Sontiq, Inc. provides identity theft, privacy and credit protection solutions to consumers, businesses and government agency clients including within the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway). We may request, gather and store personal information from individuals (our “members”) in connection with the service we provide to them.

Sontiq, Inc. will collect from its members their full name and address; email address; telephone contact numbers; other contact details as relevant for smart phone, tablet and computer; bank or other financial account and related credit card information to enable Sontiq, Inc. to keep a constant review on its’ members identity, privacy and credit in order to detect the possible illegal selling or use of a member’s personal, financial and credit information and to alert its members and their bank and/or other financial institution once any such possible illegal selling or use is detected.

Sontiq, Inc. complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Sontiq, Inc. 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. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification page, please visit http://www.privacyshield.gov.

Sontiq, Inc. respects individual privacy and values the confidence of its clients, their employees (our members), our business partners/service providers and others. Not only do we strive to store personal information in a manner consistent with the laws of the countries in which we do business, but we also have a tradition of upholding the highest ethical standards in our business practices. Sontiq, Inc. is subject to the investigatory and enforcement policies of the Federal Trade Commission. This US-EU Privacy Shield Privacy Policy (the “Policy”) sets forth the privacy principles Sontiq, Inc. follows with respect to transfers of personal information from the EEA to the United States.

EU-US PRIVACY SHIELD

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “EU-US Privacy Shield”). The EEA also has recognized the EU-US Privacy Shield as providing adequate data protection (Directive 95/46/EC ). Consistent with our commitment to protect personal privacy, Sontiq, Inc. adheres to the principles set forth in the EU-US Privacy Shield (the “EU-US Privacy Shield Principles”).

SCOPE

This EU-US Privacy Shield Privacy Policy (the “Policy”) applies to all personal information received by Sontiq, Inc. in the United States from the EEA, in any format, including electronic, paper or verbal.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Sontiq, Inc.

“Client” means any customer of Sontiq, Inc, located in the EEA, for whose employees (“members”) we provide identity theft, privacy and credit protection solutions through our servers in the United States.

“Members” means those employees of our clients for whom we provide the identity theft, privacy and credit protection solutions referred to above and also any third party consumers who may independently purchase any of these solutions through our website.

“Sontiq, Inc.” means Sontiq, Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of Sontiq, Inc. to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

PRIVACY PRINCIPLES

NOTICE:

Where Sontiq, Inc. receives, stores, or processes personal information directly from individuals (members) in the EEA, we will use and disclose such information only if consistent with the EU-US Privacy Shield Principles, and the choices made by the individuals to whom such personal information relates.

CHOICE:

Sontiq, Inc. will offer individuals (members) the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Sontiq, Inc. will provide individuals with reasonable mechanisms to exercise their choices.

ACCOUNTABILITY FOR ONWARD TRANSFER:

Sontiq, Inc. does not transfer data to third parties outside of its agents. Sontiq, Inc. will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant EU-US Privacy Shield Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), EU-US Privacy Shield certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where Sontiq, Inc. has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Sontiq, Inc. will take reasonable steps to prevent or stop the use or disclosure. Sontiq, Inc. is liable for appropriate onward transfers of personal data to third parties who do not comply with the Privacy Shield principles.

Please be aware that Sontiq, Inc. may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

SECURITY:

Sontiq, Inc. will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

DATA INTEGRITY AND PURPOSE LIMITATION:

Sontiq, Inc. may use personal information provided by individuals (members) but only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Sontiq, Inc. will take reasonable steps to ensure that personal information collected is relevant to its intended use.

ACCESS AND RECOURSE

EU Individuals have the right to access their personal information. Upon request, Sontiq, Inc. will grant individuals access to personal information that it holds about them. In addition, Sontiq, Inc. will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

ENFORCEMENT AND LIABILITY:

Sontiq, Inc. will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Sontiq, Inc. determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION:

Any questions or concerns regarding the use or disclosure of personal information should be directed to Sontiq, Inc. at the address given below. Sontiq, Inc. will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between Sontiq, Inc. and the complainant, Sontiq, Inc. has agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the EU-US Privacy Shield Principles. A resident of the European Union (EU) whose enquiry has not been satisfactorily addressed may contact either the EU DPAs panel by email to [email protected] or individual EU DPAs using the information provided at http://ec.europa.eu/justice/data-protection/bodies/index_en.htm to resolve disputes pursuant to the EU-US Privacy Shield Principles.

Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

The services of the EU DPAs panel are provided at no cost to you.

LIMITATION ON APPLICATION OF PRINCIPLES:

Adherence by Sontiq, Inc. to these EU-US Privacy Shield Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; (c) to the extent expressly permitted by an applicable law, rule or regulation; and (d) to the extent that Sontiq, Inc. has limited or no control over the actions of the individuals (members) who have provided personal information.

INTERNET PRIVACY

Sontiq, Inc. recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the “IPP”) governing the treatment of personal information collected. With respect to personal information that is transferred from the European Economic Area to the U.S., the IPP is subordinate to this Policy. Sontiq, Inc.’s Internet Privacy Policy can be found at: https://www.sontiq.com/privacy-policy/

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to Sontiq, Inc. by mail to:

Sontiq, Inc.
9920 Franklin Square Drive, Suite 250, Nottingham, MD, 21236 (Attn:Privacy Officer)

Or by e-mail to [email protected].

CHANGES TO THIS EU-US PRIVACY SHIELD PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the EU-US Privacy Shield Principles. A notice will be posted on the Sontiq, Inc. web site (https://www.Sontiq.com) for 60 days whenever this EU-US Privacy Shield Privacy Policy is changed in a material way.

EFFECTIVE DATE: July 17th, 2017