Beehive Biometrics Inc. (“BeehiveID”) has developed the following Safe Harbor Policy to protect personal information. This Statement applies to all personal information received by BeehiveID in the United States from the European Economic Area (“EEA”) or Switzerland. It applies to personal information in electronic and off-line formats.
In order to legally transfer consumer information from third parties in the European Union or Switzerland to us in the United States, we must treat transferred consumer information consistent with European and Swiss privacy principles. This policy describes how we will comply with European Union and Swiss privacy law.
This policy applies to any consumer information that we receive from our customers in Europe and Switzerland.
- A "Consumer" is a natural person that Personal Information relates to
- "Personal Information" means any information relating to an identified or identifiable natural person that is within the scope of the EU Personal Information Directive, received by BeehiveID from the European Economic Area or Switzerland, and recorded in any form. For example, Personal Information includes IP addresses, user IDs and information such as geolocation data that could be used to identify the person. Personal Information includes encrypted data for which we have a key or can otherwise feasibly decrypt, but does not include data that is hashed or otherwise modified in a way that we are unable to reconstruct or use to identify a Consumer
- "Privacy Principles" are the privacy principles consistent with European Union and Swiss law. We must treat Personal Information in accordance with these principles in order to comply with European Union and Swiss privacy law
- "Sensitive Personal Information" is Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, we will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.
European Union and Swiss privacy law requires us to treat Personal Information we process in accordance with Privacy Principles which describe the privacy rights that we must provide Consumers to comply with European and Swiss privacy law.
The Privacy Principles are:
Notice – To the extent we collect or maintain Personal Information, we will inform Consumers, through our customers or other reasonable means:
- the purposes and use of Personal Information we collect about them
- who we disclose their Personal Information to
- the choices they have to limit our use and disclosure of Personal Information about them
- how to make those choices
- how to contact us about their Personal Information.
Personal Information received from third parties may only be used as permitted by privacy policies that apply to that Personal Information
Choice – We will take reasonable steps to ensure that our customers provide Consumers with the opportunity to choose (opt-out of) whether we may use their Personal Information for any purpose not disclosed to the Consumer when the data is collected. To the extent that BeehiveID collects or maintains Personal Information directly, we will ensure that Customers are provided with the same choice to opt-out of uses of their Personal Information not disclosed when the data is collected.
For Sensitive Personal Information, we will take reasonable steps to ensure that our customers obtain adequate consent for our uses of the data. To the extent that we collect or maintain Sensitive Personal Information directly, we will ensure that Customers are provided with the same choice to opt-in to uses of their Personal Information not disclosed when the data is collected.
Where BeehiveID provides Consumers with choices regarding their Personal Information, Consumers must be provided with user-friendly mechanisms to exercise their choices.
Onward Transfers – We must obtain contractual or other enforceable assurances from third parties that they will safeguard Personal Information consistently with this Policy prior to transferring any Consumer information. Where we have knowledge that a third party is using or disclosing Personal Information in a manner contrary to this Policy, we will take reasonable steps to prevent or stop the use or disclosure.
Security – We will take reasonable precautions to secure and protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Data Integrity – Personal Information must be used only in ways that are compatible with the purposes for which it was collected, or subsequently authorized by the Consumer. We must take reasonable steps to ensure that the Personal Information it processes is necessary for its intended use, and is accurate, complete, and current.
Access and Correction – Where we collect or maintain Personal Information, we will provide Consumers reasonable access to their Personal Information. In addition, we will take reasonable steps to permit Consumers to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
Enforcement – BeehiveID utilizes the self-assessment approach to assure its compliance with our Safe Harbor statement. BeehiveID periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Safe Harbor Principles.
Any questions, concerns, or complaints concerning the collection and use of personal information by BeehiveID should be directed to the Office of the Compliance Department at the address given below. BeehiveID will conduct a reasonable investigation of and will attempt to resolve any complaints in accordance with the principles contained in this Policy. For complaints that cannot be resolved between BeehiveID and the complainant, we agree to participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles.
Change of Ownership
In the event of change in ownership, or a direct merger or acquisition with another entity, we reserve the right to transfer all User information, including Personal Data, to a separate entity. We will use commercially reasonable efforts to notify you (by posting on our website or issuing an e-mail to the e-mail address you provided when you registered) of any change of ownership; merger or acquisition of BeehiveID by a third party, and you may choose to modify any of your registration information at that time.
Exceptions to This Policy
We may disclose Personal Information if: (a) we are required to respond to a legal or ethical obligation; (b) necessary to meet national security, public interest or law enforcement obligations; or (c) expressly permitted by an applicable law, rule or regulation.
If users have any questions or suggestions regarding our Safe Harbor policy, please contact us at: +1 (512) 710-8118 or info@BeehiveID.com.
This Safe Harbor Policy was last updated on 6/14/15.