Safe Harbor Policy

Analytics Consulting LLC recognizes that privacy is very important to our customers and employees, and therefore strives to protect the personal information it collects and handles. This Policy sets forth the privacy principles that Analytics follows with respect to transfers of personal information from the EU to the US.

Analytics 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.  Analytics 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 the integrated Analytics’ certification, please visit www.export.gov/safeharbor.

Scope

This Policy applies to all personal information received by Analytics from the EU. Such personal information may pertain to Analytics employees.  It may also pertain to third party individuals in connection with Analytics providing technical and solutions support to Analytics, EU-based clients, or clients in possession or control of personal information in the EU, although Analytics personnel would in most instances not have direct contact with those third party individuals about whom such information pertains.

Definitions

The following definitions shall apply throughout this Policy:

“Agent” means any third party that uses personal information provided to Analytics to perform tasks on behalf of and under the instructions of Analytics.

“Analytics” means Analytics Consulting LLC.

“EU” means the European Union, including its member states.

“Personal information” means any information or set of information that identifies an individual, or could be used by or on behalf of Analytics to identify an individual.

“Policy” means this Safe Harbor Policy.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual’s health or sex life. In addition, Analytics will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

“US” means the United States and its territories.

Privacy Principles

The privacy principles in this Policy are based on the Safe Harbor Privacy Principles.

Notice

When Analytics collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses their personal information, the types of non-agent third parties, if any, to which Analytics discloses that information, and the choices and means, if any, that Analytics 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 Analytics, or as soon as practicable thereafter, and in any event before Analytics uses the information for a purpose other than that for which it was originally collected.

If Analytics receives personal information from other entities in the EU, it will use such information in accordance with the notices such entities provided and the consents or choices made by the individuals about whom such personal information relates.

Choice

Analytics will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party (unless allowed or required by contract), 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, Analytics will give individuals the opportunity to affirmatively and explicitly consent (e.g., through an opt-in) 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.

Analytics will provide individuals with reasonable methods to exercise their choices.

Data Integrity

Analytics will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Analytics will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. 

Onward Transfer

Analytics will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. If Analytics has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Analytics will take reasonable steps to prevent or stop the use or disclosure.

Access

Upon request, Analytics will grant individuals reasonable access to personal information that it holds about them, and Analytics will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. 

Security

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

Enforcement

Analytics will conduct compliance reviews of its relevant privacy practices to verify adherence to this Policy. Any employee that Analytics determines is in violation of 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 Analytics at the email and mailing addresses given below. Analytics 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 Analytics and the complainant, Analytics has agreed to participate in the dispute resolution procedures of the panel established by JAMS to resolve disputes pursuant to the Safe Harbor Principles.

Contact Information

Questions or comments regarding this policy should be submitted to:

Legal Department
Analytics Consulting LLC
18675 Lake Drive East
Chanhassen, MN 55317
(952) 404-5700
privacy@analyticsllc.com

Please include your name, address, and phone number or email in all communications and clearly state the nature of your request.

 Changes to this Policy

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning such changes.

 Limitation on Application of Principles

Adherence by Analytics to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation, and (b) to