Privacy Notice EEA Supplement

Privacy EEA Notice Supplement for the Citizens and Residents of the European Economic Area, United Kingdom and Switzerland

This European Economic Area (“EEA”) Privacy Notice (“EEA Notice”) supplements the information contained in the Privacy Policy of Computer Services, Inc. (“CSI”). CSI provides this EEA Notice to comply with our obligations as a company that may control and/or process personal data as a part of our business activities related to the EEA, the United Kingdom and Switzerland under the EU General Data Protection Regulation (“GDPR”), UK Data Protection Act, and Swiss Data Protection Act, as applicable. This EEA Notice must be read in conjunction with our Privacy Policy to understand all of the terms that apply to the processing of your personal data. Any capitalized term used in this EEA Notice, but not defined will have the meaning ascribed to it in the applicable privacy act or our Privacy Policy.

CSI EEA Business Activities

Our EEA business activities are primarily in regard to determining whether inquiry subjects are on restricted party screening lists maintained by governmental authorities and other organizations, including among others FBI, Interpol, U.S. Departments of Defense, State and Treasury, the EU, Australia, Canada, England, India, Ireland, Japan, Netherlands, United Nations and the World Bank. Inquiries are most often initiated by companies with which the inquiry subjects wish to engage in business and to which the inquiry subjects have given consents to the inquiries.

Single Sign On

This EEA Notice includes the information collected from you when you register for a Single Sign On (“SSO”) account. SSO is an identity provider service that creates, maintains and manages user identity information, providing authentication services for Canonical Ltd. (UK) and other third party applications. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data. For more information, please see our Privacy Policy.

With regard to the transfer of personal information from the EU, UK or Switzerland to the United States, CSI relies on the European Commission’s standard contractual clauses (SCC’s) that are currently recognized by the EU, UK and Swiss data protection authorities as an alternative data transfer mechanism and tries to implement technical measures, including encryption, that can prevent U.S., authorities from accessing any such transferred information without legal process. We also comply with the Privacy Shield Frameworks as a way to articulate and illustrate our commitment to data subject privacy and provide individuals with an additional legal recourse method that is enforceable in the United States.

Privacy Shield – For EU, UK and Swiss Data That is Transferred to the United States

CSI complies with the EU-US and Swiss-US Privacy Shield Framework(s) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield.  CSI has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit the Privacy Shield website.

CSI is subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC).

The following principles apply to EU, UK and Swiss personal data as described below while it is in the United States:

  • Individuals have the right to access their personal data and to update or correct inaccurate information or request deletion of information that has been handled in violation of the principles.
  • We may share your personal data with vendors, affiliates or other third parties as described below under “Disclosures of Your Personal Data” We remain liable for the onward transfer of personal data to third parties acting as our agents unless we can prove we were not a party giving rise to the damages.
  • We will provide individuals with opt-out choice prior to sending marketing materials.
  • Individuals wishing to pursue information rights should contact CSI at the addresses below.
  • We may be required to release information in response to lawful requests by public authorities including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, CSI commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield.  European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact CSI at: CSI, ATTN: Data Protection Officer, 3901 Technology Drive, Paducah, Kentucky 42001-5201 or emailed to privacy@csiweb.com.

CSI has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have identified in our Privacy Policy and grouped together as follows:

Category Examples
Identity Data. First name, maiden name, last name, alias, username or similar identifier, unique personal identifier, passport number, marital status, title, date of birth and gender.
Contact Data. Postal address, mailing address, email address and telephone numbers
Technical Data. Internet Protocol address, login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on devices.
Profile Data. Username, password, interests, preferences, feedback and survey responses.
Geolocation Data. Physical location of device.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data (GDPR Article 9) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about your criminal convictions and offences, if any, except to the extent that criminal conduct has resulted in your being listed on a restricted party screening list.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How We Collect Your Personal Data

Please see the section entitled “Information We Collect about You and How We Collect It” in our Privacy Policy to see how we collect your personal data.

How We Use Your Personal Data

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform a contract we are about to enter into or have entered into with you or a contract between you and a third party under which you have given your consent to providing personal data.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.
Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Lawful basis for processing including basis of legitimate interest
To register you as a new user Performance of a contract with you or a contract between you and a third party under which you have given your consent to providing personal data
To manage our relationship with you which will include:
(a) Provide you with information or services that you request from us
(b) Respond to your comments, questions, and requests, and provide customer service
(c) Notifying you about changes to our Terms of Use or Privacy Policy
(d) Asking you to leave a review or take a survey 		(i) Performance of a contract with you or a contract between you and a third party under which you have given your consent to providing personal data
(ii) Necessary to comply with a legal obligation
(iii) Necessary for our legitimate interests (to respond to our clients’ and users’ requests; to keep our records updated; and to study how customers use our products or services)
To administer and protect our business and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (i) Necessary to comply with a legal obligation
(ii) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection (i) Performance of a contract with you or a contract between you and a third party under which you have given your consent to providing personal data
(ii) Necessary to comply with a legal obligation
(iii) Necessary for our legitimate interests (for running our business)
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Sites, services, marketing, customer relationships and experiences Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you Necessary for our legitimate interests (to develop our products/services and grow our business)
To conduct recruiting and candidate evaluation activities and to inform our employment decisions Necessary for our legitimate interests (to recruit and hire proper and qualified candidates)
For legal and operational compliance purposes:
(a) monitor our compliance with this policy;
(b) detect and protect us against error, negligence, breach of contract, fraud, theft, and other illegal activity, and to audit compliance with our policies and contractual obligations
(c) evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets 		(i) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(ii) Necessary to comply with a legal obligations
(iii) Necessary for us to provide a service in furtherance of a substantial public interest
Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers From Us

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing or other information.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out

You can ask us to stop sending you marketing or other informational messages at any time by contacting us by email at privacy@csiweb.com.

Where you opt out of receiving these marketing and other informational messages, this will not apply to personal data provided to us as a result of a service or work that we performed for you or other similar transactions.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Our affiliated companies.
  • Our customers.
  • Our vendors.
  • Our service providers.
  • Other third parties to protect our legal rights or comply with legal requirements.
  • Other third parties as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • Other third parties involved in a merger, sale, joint venture or other transaction involving a transfer of our business or assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in our Privacy Policy.
  • Other third parties with your prior consent.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We are a service company based in the United States and provide various services for companies in the EEA, the UK and Switzerland. To perform our services and comply with our contractual obligations with our clients, we may share your personal data outside the EEA, the UK or Switzerland.

We recognize that many countries globally have regulations restricting the flow of personal data across international borders. We have put in place measures to ensure that adequate protection is provided to such data where legally mandated. Whenever we transfer your personal data out of the EEA, the UK or Switzerland, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • We comply with the US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data transferred to the EEA, UK and Switzerland from the United States. With regard to the transfer of personal data from the EEA, UK, or Switzerland to the United States, we rely on the European Commission’s standard contractual clauses, which are currently recognized by the EU, UK and Swiss data protection authorities as an alternative data transfer mechanism, and we try to implement technical measures, like encryption, that can prevent US authorities from accessing any such transferred data.

Data Security

Please see the section entitled “How We Protect Your Personal Information” in our Privacy Policy to see how we protect your personal data.

Data Retention — How Long Will We Use Your Personal Data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Period in which To Respond

We try to respond to all legitimate requests within one (1) month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Glossary of Terms

Lawful Basis means any of the six (6) bases listed in Article 6.1(a)-(f) of the GDPR, including those reflected in the right column of the Purposes table, above.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

General

Complaints

You have the right to make a complaint at any time to the proper authority for data protection issues; however, we would appreciate the chance to deal with your concerns before you approach these authorities.

Communications

Communications, queries, complaints or requests to exercise informational rights can be addressed to CSI, ATTN: Data Protection Officer, 3901 Technology Drive, Paducah, Kentucky 42001-5201 or emailed to privacy@csiweb.com.

Changes to this EEA Notice

We reserve the right to amend this EEA Notice at our discretion and at any time. When we make changes to this EEA Notice, we will post the updated notice to our Site and update the “Last Reviewed” date. Your continued use of our Site and Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy and this EEA Notice periodically for updates.

Contact Us

If you have any questions regarding this Privacy Policy or the practices of our Sites, please contact us at:

Computer Services, Inc. (CSI)
ATTN: Data Protection Officer
3901 Technology Drive
Paducah, Kentucky 42001-5201
privacy@csiweb.com
800.545.4274

Last Reviewed: May 3, 2021