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We self-certify compliance with
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the “Safe Harbor Principles”) to enable U.S. Companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. Consistent with its commitment to protect personal privacy, nowHIRE.com adheres to the Safe Harbor Principles.
For purposes of this Policy, the following definitions will apply:
“Agent” means any third party that uses personal information provided by nowHIRE.com to perform tasks on behalf of and under the instruction of nowHIRE.com.
“nowHIRE.com” means Interactive Solutions Group, Inc., its predecessors, successors, affiliates and subsidiaries.
“Personal Information” means any information or set of information that identifies or is used by or on behalf of nowHIRE.com 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.
“Sensitive Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, or information that concerns an individual’s health. In addition, nowHIRE.com will treat, as sensitive personal information, any information received from a third party where that third party treats and identifies the information as sensitive.
This Policy applies to all personal information received by nowHIRE.com in the United States from the EU, in any format including electronic, paper, or verbal.
Where nowHIRE.com collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses the information, the types of third parties to which nowHIRE.com discloses that information, and the choices and means, if any, nowHIRE.com offers individuals 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 nowHIRE.com, or as soon as practicable thereafter, and in any event before nowHIRE.com uses the information for a purpose other than that for which it was originally collected.
Where nowHIRE.com receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
nowHIRE.com will offer individuals 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.
For sensitive information, nowHIRE.com will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a third party or to the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
TRANSFERS TO AGENTS
nowHIRE.com may share an individual’s information with agents, contractors, or partners of nowHIRE.com in connection with services that these individuals or entities perform for, or with, nowHIRE.com.
nowHIRE.com will obtain assurances from its agents and contractors that they will safeguard personal information received from us in a manner consistent with this Policy. Appropriate assurance of compliance may be given in a number of ways, which may include one or more of the following:
||A contract between nowHIRE.com and the third party which includes provisions requiring the third party to provide at least the same level of protection as is required by the relevant Safe Harbor Principles.
||The third party may be subject to the EU Data Protection Directive itself.
||The third party may have filed its own Safe Harbor certification.
Where nowHIRE.com has knowledge that an agent, contractor, or partner is using or disclosing personal information in a manner contrary to this Policy, we will take reasonable steps to prevent or stop the use or disclosure.
nowHIRE.com will employ reasonable safeguards to protect personal information in its possession. To prevent unauthorized access, disclosure, and destruction of personal information and to maintain data accuracy and ensure the appropriate use and confidentiality of the personal information, either for nowHIRE.com’s own purposes or on behalf of our customers, nowHIRE.com has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal information nowHIRE.com processes.
nowHIRE.com processes personal information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, nowHIRE.com takes reasonable steps to ensure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.
ACCESS AND CORRECTION
Upon request, individuals will be granted reasonable access to personal information that is maintained by nowHIRE.com. If an individual becomes aware that the personal information is inaccurate, the individual may contact nowHIRE.com using the contact information below. Upon receipt of such request, nowHIRE.com will take reasonable steps to permit individuals to correct, amend, or delete information that is found to be inaccurate or incomplete.
nowHIRE.com periodically verifies that this Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Safe Harbor Principles. All reported breaches or potential breaches will be investigated by the Privacy Officer and the investigative agents the Officer assigns, who will take such actions as they deem appropriate in the investigation, and if necessary, remediate the situation. Any employee that nowHIRE.com determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.
Any questions or concerns regarding the use or disclosure of personal information should be directed to the Privacy Officer at the address given below. nowHIRE.com will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the Safe Harbor Principles contained in this Policy. For complaints that cannot be resolved between nowHIRE.com and the complainant, nowHIRE.com has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.
Questions or comments regarding this Policy should be submitted to the nowHIRE.com Privacy Officer by mail as follows:
Corporate Immigration Counsel
21220 Kelly Road
Eastpointe, Michigan 48021
LIMITATION ON APPLICATION
Adherence by nowHIRE.com to the Safe Harbor Principles may be limited (a) to the extent we are required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule, or regulation.
This Policy may be amended from time to time, consistent with the requirements of
the Safe Harbor Principles. Notice of any such amendment will be posted to this