Privacy Shield Policy
Last Updated: May 16, 2018
Istizada L.L.C. (“Istizada”) respects your concerns about privacy. Istizada complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (collectively “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Istizada has certifies to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this 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, please visit https://www.privacyshield.gov/
For purposes of this Policy:
“Consumer” means any natural person who is located in the EU or Switzerland, but excludes any individual acting in his or her capacity as an Employee.
“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
“Employee” means any current, former or prospective employee, temporary worker, intern or other non-permanent employee of any subsidiary or affiliate of Istizada, who is located in the EU or Switzerland.
“EU” means the European Union and Iceland, Liechtenstein and Norway.
“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Istizada in the U.S. from the EU or Switzerland, and (iii) recorded in any form.
“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.
“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.
“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.
“Supplier” means any supplier, vendor or other third party located in the EU or Switzerland that provides services or products to Istizada.
Types of Personal Data Istizada Collects
- Contact information, such as name, postal address, email address and telephone number; and
- Personal Data in content Consumers provide on Istizada’s website and other data collected automatically through the website (such as IP addresses, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our website, and dates and times of website visits).
In addition, Istizada obtains Personal Data, such as contact information and financial account information, of its Suppliers’ representatives. Istizada uses this information to manage its relationships with its Suppliers, process payments, expenses and reimbursements, and carry out Istizada’s obligations under its contracts with the Suppliers.
Istizada also may obtain and use Consumer Personal Data in other ways for which Istizada provides specific notice at the time of collection.
Istizada’s privacy practices regarding the processing of Consumer Personal Data comply with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.
Relevant information also may be found in notices pertaining to specific data processing activities.
Istizada generally offers Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the Privacy Shield Principles, Istizada obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact Istizada as indicated below regarding the company’s use or disclosure of their Personal Data. Unless Istizada offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy.
Istizada shares Consumer Personal Data with its affiliates and subsidiaries. Istizada may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. Istizada also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).
Accountability for Onward Transfer of Personal Data
Except as permitted or required by applicable law, Istizada provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Istizada requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (iii) notify Istizada and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.
With respect to transfers of Consumer Personal Data to third-party Processors, Istizada (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Istizada’s obligations under the Privacy Shield Principles, (v) requires the Processor to notify Istizada if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Istizada remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Istizada proves that it is not responsible for the event giving rise to the damage.
Istizada takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data. Some of the ways we protect personal data includes but is not limited to limiting personal data access to only a few team members that need access to the data, regular password changes, hosting our data on some of the most secure servers in a dedicated environment through WPEngine, one of these most secure hosting providers around. Other Security measures include extensive courses team members are required to go through to access personal information and a general principle that everyone on the team is responsible for data protection.
Data Integrity and Purpose Limitation
Istizada limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. Istizada does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes, Istizada takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Istizada relies on its Consumers to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact Istizada as indicated below to request that Istizada update or correct relevant Personal Data.
Subject to applicable law, Istizada retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer.
Consumers generally have the right to access their Personal Data. Accordingly, where appropriate, Istizada provides Consumers with reasonable access to the Personal Data Istizada maintains about them. Istizada also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. Istizada may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting Istizada as indicated below.
Recourse, Enforcement and Liability
Istizada has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Istizada conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Istizada makes about its Privacy Shield privacy practices are true and that Istizada’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.
Consumers may file a complaint concerning Istizada’s processing of their Personal Data. Istizada will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact Istizada as specified below about complaints regarding Istizada’s Consumer Personal Data practices.
If a Consumer’s complaint cannot be resolved through Istizada’s internal processes, Istizada will cooperate with JAMS pursuant to the JAMS International Mediation Rules, available on the JAMS website at www.jamsadr.com/international-mediation-rules. JAMS mediation may be commenced as provided for in the relevant JAMS rules. The mediator may propose any appropriate remedy, such as deletion of the relevant Personal Data, publicity for findings of noncompliance, payment of compensation for losses incurred as a result of noncompliance, or cessation of processing of the Personal Data of the Consumer who brought the complaint. The mediator or the Consumer also may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over Istizada. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Istizada’s compliance with the Privacy Shield Principles.
Istizada will undertake an annual review of our privacy compliance in order to make sure Istizada remains in compliance with Privacy Shield principles before renewing its Privacy Shield certification. This review will include but not be limited to reviewing our Notice Policies, Choice Policies, Access Policies, Privacy Training, Accountability for Onward Transfer, Data Security, Any Complaints, Data integrity, Data Purpose and Recourse Availability.
How to Contact Istizada
To contact Istizada with questions or concerns about this Policy or Istizada’s Consumer Personal Data practices:
2533 Far Hills Ave
Dayton, Ohio 45419
E-mail: [email protected]