PRIVACY SHIELD PRIVACY POLICY FOR CUSTOMER DATA
Communication Constructs, Inc. (“CCI”), d/b/a Opti.Co is committed to upholding the highest ethical standards in its business practices and strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business. This Privacy Shield Privacy Policy sets forth the privacy principles that CCI follows with respect to personal information transferred from the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.


COMMUNICATION CONSTRUCTS, INC. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework 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.  (Your organization name) has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms 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, please visit https://www.privacyshield.gov/

PRIVACY SHIELD

SCOPE
This PRIVACY SHIELD Privacy Policy (the "Policy") applies to all personal information received by CCI in the United States from the European Economic Area and from Switzerland, 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, CCI or to which CCI discloses personal information for use on CCI's behalf.

"CCI" means Communication Constructs, Inc., its successors, subsidiaries, divisions and groups in the United States.

"Personal information" means any information or set of information that identifies or is used by or on behalf of CCI 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 personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, CCI will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.



PRIVACY PRINCIPLES
The privacy principles in this Policy are based on the PRIVACY SHIELD Principles.

NOTICE: Where CCI collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them and the choices and means, if any, CCI 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 CCI, or as soon as practicable thereafter, and in any event before CCI uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a non-agent third party.

Where CCI receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: For personal information, CCI will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent 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 personal information, CCI will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

CCI will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: CCI will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. CCI will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. We will only collect and store personal information that is relevant to fulfill the purpose of the request and will retain such information no longer than appropriate to fulfill the purpose of the request.

TRANSFERS TO AGENTS: CCI 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 PRIVACY SHIELD Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), PRIVACY SHIELD certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where CCI has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, CCI will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, CCI will grant individuals reasonable access to personal information that it holds about them. In addition, CCI will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. These requests can be made by contacting our Data Privacy Department at http://www.opti.co/dataprivacy, by email at dataprivacy@opti.co, or by mail as follows: Communication Constructs, Inc., Data Privacy Department, P.O. BOX 56967, Albuquerque, New Mexico 87187.

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

ENFORCEMENT: CCI will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that CCI determines intentionally violates 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 the CCI Data Privacy Department at the address given below. CCI will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between CCI and the complainant, CCI has agreed to participate in the dispute resolution procedures of the American Arbitration Association pursuant to the PRIVACY SHIELD Principles.

LIMITATIONS ON APPLICATION OF PRINCIPLES
Adherence by CCI to these PRIVACY SHIELD Principles may be limited (a) to the extent required or permitted by law or legal process, such as to respond to or investigate a legal or ethical obligation or request or pursuant to court orders, subpoenas, interrogatories or similar directive carrying the force of law; and (b) to the extent expressly permitted by an applicable law, rule or regulation.

INTERNET PRIVACY
CCI sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers. CCI 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 through web sites that it operates. With respect to personal information that is transferred from the European Economic Area or Switzerland to the U.S., the IPP is subordinate to this Policy. However, the IPP also reflects additional legal requirements and evolving standards with respect to Internet privacy. CCI’s Internet Privacy Policy can be found at http://www.opti.co/dataprivacy.

CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to the CCI Data Privacy Department by mail as follows:

www.Opti.Co
dataprivacy@opti.co

Communication Constructs, Inc.
Data Privacy Department
P.O. BOX 56967
Albuquerque, New Mexico 87187


CHANGES TO THIS PRIVACY SHIELD PRIVACY POLICY
This Policy may be amended consistent with the requirements of the PRIVACY SHIELD Principles. A notice will be posted on the CCI web page (www.opti.co/DataPrivacy) for 60 days whenever this Privacy Policy is changed in a material way.

EFFECTIVE DATE

November 14, 2017

 

Data Privacy Policy