Date of Last Revision: October 21, 2020
DATA PRIVACY AT MOVERE, INC.
Movere, Inc. (“Movere”) has established a comprehensive privacy program designed to protect your data privacy rights.
EU-U.S. AND SWISS-U.S. PRIVACY SHIELD FRAMEWORKS
The following provisions govern information collected in reliance on the EU-U.S. and Swiss-U.S. Privacy Shield Framework Principles for transfers of personal data from the EU and Switzerland to the United States. Movere adheres to the EU-U.S. and Swiss-U.S. Privacy Shield Principles (“Principles”) and is committed to subject to the Principles all personal data received from the EU and Switzerland in reliance on the Privacy Shield. Individuals from whom Movere collects personal information under the Privacy Shield have the right to access their personal data by contacting Movere at email@example.com. As a result of certification to the EU-U.S. and Swiss-U.S. Privacy Shield Privacy Shield, Movere is subject to the investigatory and enforcement powers of the FTC.
Movere may be required to disclose personal information pursuant to lawful requests made by public authorities, including to meet national security or law enforcement requirements.
INQUIRIES AND COMPLAINTS
We take safeguarding your privacy very seriously. If you wish to verify, correct or delete any personal information we have collected, or if you have any questions or concerns, or if you have any complaints, please contact our Data Protection Officer at firstname.lastname@example.org.
If you filed a complaint with Movere and it has not been properly addressed, JAMS is designated by Movere as the independent dispute resolution body to address complaints regarding Movere’s collection of personal information and provide appropriate recourse. Such body will not charge the complaining party for its services. Follow this link: https://www.jamsadr.com/eu-us-privacy-shield to the complaint submission form for the above referenced independent dispute resolution body.
If your claims as to data covered by the EU-U.S. and Swiss-U.S. Privacy Shield have not been remedied through dispute resolution directly with Movere or through independent dispute resolution as described above, such “residual claims” may be heard by a “Privacy Shield Panel” composed of one or three arbitrators as agreed upon by the parties. The Privacy Shield Panel may only award individual-specific, non-monetary equitable relief (e.g. access, correction, deletion of the individual’s data in question) necessary to remedy the violation of the Principles only with respect to the individual. Damages, costs, fees and other remedies may not be awarded, and each party bears its own attorney’s fees. This arbitration option is only available for an individual to determine for such “residual claims” whether Movere has violated its obligations under the Principles as to that individual and whether any such violation remains fully or partially unremedied.
When Movere collects personal information from individuals, it will inform the individual of the purpose for which it collects and uses the personal information and the types of non-agent third parties to which Movere discloses or may disclose that information. Movere shall provide the individual with the choice and means for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Movere, or as soon as practicable thereafter, and in any event before Movere uses or discloses personal information for a purpose other than for which it was originally collected.
In instances in which Movere is not the controller or collector of the personal information, but only a processor, it has no means of providing individuals with the choice and means for limiting the use and disclosure of their personal information or providing notices when individuals are first asked to provide personal information to Movere. In such instances, Movere will comply with the instructions of the controller of such information; provide appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and to the extent appropriate, assist the controller in responding to individuals exercising their rights under the Principles.
In those instances in which Movere collects personal information from individuals, it will offer individuals the opportunity to choose (opt out) whether their personal information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
DISCLOSURES TO THIRD PARTIES
In those instances in which Movere collects personal information from individuals, prior to disclosing personal information to a third party, Movere shall notify the individual of such disclosure and allow the individual the choice to opt out of such disclosure. Movere shall ensure that any agent third party for which personal information may be disclosed subscribes to these principles or are subject to law providing the same level of privacy protection as is required by these principles and agree in writing to provide an adequate level of privacy protection. When Movere acts as a collector and processor of information it receives from employers regarding their employees and/or contractors, or from entities that obtained such information from those employers, Movere may obtain the name and email address of persons using devices onto which Microsoft products are installed together with machine identification numbers for such devices. In such instances, Movere will use such information only for purposes of performing software license utilization analysis and then providing such information back to the entity that provided it to Movere. Movere would only disclose personal information to third parties for the above stated purposes and would remain liable under the Principles if its agents were to process such personal information in a manner inconsistent with the Principles, unless Movere is able to show that it is not responsible for the event giving rise to the damage. Data shared with Movere, may be assigned without your consent by Movere to (i) a parent or subsidiary, (ii) an acquirer of assets, or (iii) a successor by merger.
Movere shall take reasonable steps to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Movere has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Movere cannot guarantee the security of information on or transmitted via the Internet.
Movere shall only process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by those who provided the information. To the extent necessary for those purposes, Movere shall take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.
In those instances in which Movere collects personal information directly from individuals, Movere shall allow those individuals access to their personal information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
GDPR (GENERAL DATA PROTECTION REGULATION)
The GDPR replaces Directive 95/46/EC and becomes enforceable on May 28, 2018. The following statement is intended to supplement the preceding discussion of the EU-U.S. and Swiss-U.S. Privacy Shield. As to personal data collected and controlled by Movere, EU data subjects retain their full rights to be informed of the purposes of our processing activities at collection; to withdraw consent; to access, rectify, transport, and erase their personal data; to object to processing for direct marketing efforts; and to object when subjected to automated processing decisions. As to personal data collected by third parties, and as to which Movere is a mere processor, EU data subjects should contact the controller with regard to their rights to be informed of the purposes of our processing activities at collection; to withdraw consent; to access, rectify, transport, and erase their personal data; to object to processing for direct marketing efforts; and to object when subjected to automated processing decisions. We do not intentionally collect personal data from, and do not tailor any services to, children.
Our Data Protection Officer – KRISTIN IRELAND – will assist EU residents with these requests free of charge and may be contacted at email@example.com.
Movere understands that the adoption of global data security practices is not a one-time activity.
MOVERE’S “PRIVACY BY DESIGN” APPROACH REQUIRES THAT OUR DEFAULT USER DATA PROTECTION LEVELS BE AT THE HIGHEST SETTING BY DEFAULT. IN THE UNLIKELY EVENT OF BREACH, MOVERE WILL NOTIFY DATA SUBJECTS AND SUPERVISORY AUTHORITIES (SAS) IN THE EU ACCORDING TO PROCEDURES PROVIDED IN GDPR ARTICLES 33 AND 34.
(WHEN MOVERE COLLECTS PERSONAL INFORMATION FROM INDIVIDUALS THROUGH ITS WEBSITES)
HOW WE COLLECT INFORMATION
We do not collect any personal information from mere visitors to our site. We do not collect any personal information unless you choose to provide it. We may request this personal information when a product or demo is downloaded, for subscriptions, or when additional information about our products or services is requested. When you visit our site, some information is also automatically collected through the use of log files, such as your computer’s Internet Protocol (IP) address. Such non-personal information could become “personal information” if correlated with other information that identifies you, such as your name, email address, etc. However, when gathered from individuals through our websites, we use this information only for purposes such as analying trends, administering websites, improving customer service, diagnosing problems with our servers, tracking user movement, and gathering broad demographic information for aggregate use, not for the purposes of identifying individuals.
HOW WE USE INFORMATION
We collect, store and use personal information provided by you to better understand customer needs, as well as to determine how we can improve our products and services. With your permission, we may also use this personal information to contact you with announcements and promotions or with questions about your account that may arise.
PROTECTING PERSONAL INFORMATION
In some instances we collect information that is not personally identifiable. Examples of this type of information include the type of computer operating system used, the type of Web browser used, or the domain name of the websites which linked to our site. This information helps us analyse trends, administer our site and gather broad demographic information for aggregate use. We do not share, rent or sell non-identifiable information.
When you view our websites, we may store a small amount of data on your computer. This data is in the form of a “cookie.” It can only be read by the server that sent it. Cookies act as a way to record passwords, orders, and preferences for visiting our site. In addition, cookies allow us to remember you across pages of our websites or multiple visits. This saves you time by eliminating the need to re-enter information each time you access a password-protected page. Most Web browsers allow you to erase cookies, block cookies, or receive a warning before a cookie is stored. Refer to your browser’s instructions or help screen to learn more about these functions.
WEB USAGE ANALYTICS
We will not allow any third party to use the statistical analytics tools to track or collect any personal information or to associate any data gathered from the site with any personal information from any source.
DECLINING EMAIL OFFERS
You may unsubscribe from a particular email list (other than service-related emails) at any time by selecting the “unsubscribe” option within the body of the email. All email offers that you receive from Movere inform you of how to decline receiving further offers.
CHANGES TO POLICY
We take safeguarding your privacy very seriously. If you wish to verify, correct or delete any personal information we have collected, if you have any questions or concerns, if you would like to be removed from a mailing list, or if you have any complaints, please contact our Subscription Services Manager at firstname.lastname@example.org.