Intecrowd Safe Harbor Policy

INTECROWD LLC respects individual privacy and values the confidence of its customers, employees, business partners and others. Not only does INTECROWD LLC strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This privacy policy applies to all personal information received by INTECROWD LLC whether in electronic, paper or verbal format.

Safe Harbor Privacy Policy Statement

INTECROWD LLC complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. INTECROWD LLC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view INTECROWD LLC’s certification, please visit info.adr.org/safeharbor/

Definitions

“Personal Information” or “Information” means information that (1) is transferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

Principles

Notice

INTECROWD LLC shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which INTECROWD LLC discloses or may disclose that Information. INTECROWD LLC 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 INTECROWD LLC, or as soon as practicable thereafter, and in any event before INTECROWD LLC uses or discloses the Information for a purpose other than for which it was originally collected.

Choice

INTECROWD LLC 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. For Sensitive Personal Information, INTECROWD LLC will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. INTECROWD LLC shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

Onward Transfers

Prior to disclosing Personal Information to a third party, INTECROWD LLC shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. INTECROWD LLC shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.

Data Security

INTECROWD LLC shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. INTECROWD LLC 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. INTECROWD LLC cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity

INTECROWD LLC 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 the individual. To the extent necessary for those purposes, INTECROWD LLC shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access

INTECROWD LLC shall allow an individual 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.

Enforcement

INTECROWD LLC uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using the International Centre For Dispute Resolution as a third party resolution provider. They can be contacted as follows:

  1. Online: info.adr.org/safeharbor/
  2. Fax: 877-304-8457 (USA) | 212-484-4178 (Outside USA)
  3. Mail:
    International Centre for Dispute Resolution
    Case Filing Services
    120 Broadway, 21st Fl. New York, NY 10271

Personal Information Processes

In the course of delivering services to its customers, INTECROWD LLC processes data, including Personal Information, on behalf of its customers. In this context, INTECROWD LLC acts as a data processor and does not control the data. INTECROWD LLC processes Customer Data under the direction of its Customers, and has no direct control or ownership of the personal data it processes. Customers are responsible for complying with any regulations or laws that require providing notice, disclosure and/or obtaining consent prior to transferring the data to Workday or alternative system for processing purposes.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his or her query to the INTECROWD LLC Customer (the data controller). If the Customer requests INTECROWD LLC to remove the personal data to comply with data protection regulations, INTECROWD LLC will respond to their request within 30 business days.

INTECROWD LLC will refer any request for disclosure of personal data by a law enforcement authority to the Customer. INTECROWD LLC may, where it concludes that it is legally obligated to do so, disclose personal data to law enforcement or other government authorities. INTECROWD LLC will notify Customer of such request unless prohibited by law.

Information Subject to Other Policies

INTECROWD LLC is committed to following the Principles for all Personal Information with the scope of the Safe Harbor Agreement. However, certain information is subject to policies of INTECROWD LLC that may differ in some respects from the general policies set forth in this privacy policy.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of Safe Harbor. We will make this policy and any revisions publicly available on our website.

Please contact the following with any questions regarding this policy:

INTECROWD LLC
Attention: Compliance Department
7189 Lake Island Drive
Lake Worth, FL 33467
Phone: 561-346-1096
Email: compliance@intecrowd.com