SEE Forge Mobile Solutions SEE Forge Mobile Solutions

Privacy Shield Policy

Purpose of data collection

SEE Forge is a no-code application Software as a Service that allows non programmers to quickly build, deploy, and manage sophisticated forms, workflows, and enterprise-ready business applications in the cloud. All customer related personal information received by our customers is maintained in Microsoft Azure. Employees may have access to such data in order to monitor the system for security purposes and at the customer’s request, for support or professional services. SEE Forge treats all personal information originating from the European Union, either in its Cloud offering, received from employees or applicants and any potential personal data received via its website in accordance with the confidentiality conditions agreed upon with the customer and the EU-US Privacy Shield’s principles. SEE Forge utilizes third party software vendors to maintain its cloud offering who will have access to personal data, specifically Microsoft Azure.

 

Privacy Policy
(Privacy Shield Policy – www.seeforge.com/privacy-shield-policy/)

SEE Forge INC a Delaware company (SEE Forge) complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data (as defined below) from European Union member countries and Switzerland. SEE Forge has certified that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability. If there is any conflict between the policies in SEE Forge’s Privacy Shield Policy (“Privacy Shield 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 page, please visit https://www.privacyshield.gov/.

 

Definitions

“Data Owner” means the individual to whom any given Personal Data covered by this Privacy Shield Policy refers.

“Personal Data” means any information relating to an individual residing in the European Union and Switzerland that can be used to identify that individual either on its own or in combination with other readily available data.

“Sensitive Personal Data” means Personal Data regarding an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual life.

 

Scope and Responsibility

This Privacy Shield Policy applies to Personal Data transferred from European Union member countries and Switzerland to SEE Forge’s operations in the U.S. in reliance on the respective Privacy Shield framework and does not apply to Personal Data transferred under Standard Contractual Clauses or any approved derogation from the EU Directive.

Some types of Personal Data may be subject to other privacy-related requirements and policies.

 

For example:

Personal Data held by an SEE Forge customer using SEE Forge and its Software as a Service Platform FAT FINGER is also subject to any specific agreement with, or notice to, the customer, as well as additional applicable laws and professional standards.

Employee Personal Information is subject to internal human resource policies including the Employee Data Privacy Notice.

All SEE Forge employees that have access in the U.S. to Personal Data covered by this Privacy Shield Policy are responsible for conducting themselves in accordance with this Privacy Shield Policy. Adherence by SEE Forge to this Privacy Shield Policy may be limited to the extent required to meet legal, regulatory, governmental, or national security obligations, but Personal Data covered by this Privacy Shield Policy shall not be collected, used, or disclosed in a manner contrary to this policy without the prior written permission of SEE Forge CEO.

SEE Forge employees responsible for engaging third parties to which Personal Data covered by this Privacy Shield Policy will be transferred are responsible for obtaining appropriate assurances that such third parties have an obligation to conduct themselves in accordance with the applicable provisions of this Privacy Shield Principles, including any applicable contractual assurances required by Privacy Shield.

 

Privacy Shield Principles

SEE Forge commits to subject to the Privacy Shields’ Principles all Personal Data received by SEE Forge in the U.S. from European Union member countries and Switzerland in reliance on the respective Privacy Shield framework.

  1. Notice

SEE Forge notifies Data Owners covered by this Choice Privacy Shield Policy about its data practices regarding Personal Data received by SEE Forge in the U.S., from European Union member countries and from Switzerland in reliance on the respective Privacy Shield framework, including:
(i) the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data,
(ii) the types of third parties to which it discloses such Personal Data and the purposes for which it does so,
(iii) the rights of Data Owners to access their Personal Data,
(iv) the choices and means that SEE Forge offers for limiting its use and disclosure of such Personal Data,
(v) how SEE Forge obligations under the Privacy Shield are enforced,
(vi) and how Data Owners can contact SEE Forge with any inquiries, updates or complaints.

  1. Choice

If Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a third party, SEE Forge will provide Data Owners with an opportunity to choose whether to have their Personal Data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to support@seeforge.com.

If Sensitive Personal Data covered by this Privacy Shield Policy are to be used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized, or the Personal Data is to be disclosed to a third party, SEE Forge will obtain the Data Owner’s explicit consent prior to such use or disclosure.

  1. Accountability for Onward Transfer

In the event SEE Forge transfers Personal Data covered by this Privacy Shield Policy to a third party acting as a controller, SEE Forge will do so consistent with any notice
provided to Data Owners and any consent they have given, and only if the third party has given us contractual assurances that it will:
(i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Owners,
(ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify SEE Forge if it makes a determination that they cannot do so,
(iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if they make such a determination.

If SEE Forge has knowledge that a third party acting as a controller is processing Personal Data covered by this Privacy Shield Policy in a way that is contrary to the Privacy Shield Principles, SEE Forge will take reasonable steps to prevent or stop such processing.

Employment-related operational needs with respect to personal data transferred under the Privacy Shield for activities such as the booking of a flight, hotel room, or insurance coverage, transfers of personal data of a small number of employees can take place to controllers without application of the Access Principle or entering into a contract with the third-party controller, provided that the Privacy Shield organization has complied with the Notice and Choice Principles.

With respect to SEE Forge Partners, we will transfer only the Personal Data covered by this Privacy Shield Policy needed for a Partner to deliver to its customers the SEE Forge product or service. Furthermore, SEE Forge will:

(i) permit the Partner to process such Personal Data only for limited and specified purposes,
(ii) require the Partner to provide at least the same level of privacy protection as is required by the Privacy Shield Principles,
(iii) take reasonable and appropriate steps to ensure that the Partner effectively processes the Personal Data transferred in a manner consistent with SEE Forge obligations under the Privacy Shield Principles,
(iv) require the Partner to notify SEE Forge if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles.

Upon receiving notice from a Partner that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, SEE Forge will take reasonable and appropriate steps to stop and remediate unauthorized processing.

SEE Forge remains liable under the Privacy Shield Principles if a Partner processes Personal Data covered by this Privacy Shield Policy in a manner inconsistent with the Principles, except where SEE Forge is not responsible for the event giving rise to the damage.

  1. Security

SEE Forge takes reasonable and appropriate measures to protect Personal Data covered by this Privacy Shield Policy from loss, misuse, unauthorized access, disclosure, alteration, and destruction. This is done while taking into account the risks involved in the processing and the nature of the Personal Data.

  1. Data Integrity and Purpose Limitation

SEE Forge limits the collection of Personal Data covered by this Privacy Shield Policy to information that is relevant for the purposes of deploying SEE Forge product and services. SEE Forge does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Owner.

SEE Forge takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. SEE Forge takes reasonable and appropriate measures to comply with the requirement under the Privacy Shield to retain Personal Data in identifiable form only for as long as it serves a purpose of processing, which includes SEE Forge‘s obligations to comply with professional standards, SEE Forge‘s business purposes and unless a longer retention period is permitted by law, and the Privacy Shield Principles are adhered to for as long as SEE Forge retains such Personal Data.

  1. Access

Data Owners whose Personal Data is covered by this Privacy Shield Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the Privacy Shield Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Owner’s privacy, or where the rights of persons other than the Data Owner would be violated).

Requests for access, correction, amendment, or deletion should be sent to support@seeforge.com

  1. Recourse, Enforcement, and Liability

SEE Forge’s participation in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework is subject to investigation and enforcement by the Federal Trade Commission.

In compliance with the Privacy Shield Principles, SEE Forge commits to resolve complaints about your privacy and our collection or use of your Personal Data. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact SEE Forge at support@seeforge.com

SEE Forge has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.

In certain conditions, the individual has the right to invoke binding arbitration. Data Owners with inquiries or complaints regarding this Privacy Shield Policy should first contact SEE Forge at support@seeforge.com

SEE Forge is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

SEE Forge agrees to periodically review and verify its compliance with the Privacy Shield Principles, and to remedy any issues arising out of failure to comply with the Privacy

Shield Principles. SEE Forge acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Privacy Shield participants.

Changes to this Privacy Shield Policy

This Privacy Shield Policy may be amended from time to time consistent with the requirements of the Privacy Shield. Appropriate notice regarding such amendments will be given.

Dispute Resolution

NON-HR RECOURSE MECHANISM

EU Data Protection Authorities (DPAs)