20/20 Software, Inc. hosts websites and enterprise management systems (EMS) for clients in the European Economic Area (EEA) as well as the United Kingdom. We do not request, nor gather, nor store personal information about any individuals on our own behalf or for any purpose of our own. We provide a safe and secure storage and processing facility for such information gathered by our clients on their websites and EMS hosted by us.
Note: It must be emphasized that 20/20 Software, Inc. does not have control over the uses to which our clients may make of personal information disclosed to them.
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, 20/20 Software, Inc..
"Client" means any customer of 20/20 Software, Inc., located in the EEA and the United Kingdom, for whom we host a website or enterprise management system on our servers in the United States. "20/20 Software, Inc." means 20/20 Software, Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States.
"Personal information" means any information or set of information that identifies or could be used by or on behalf of 20/20 Software, Inc. 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.
20/20 Software, Inc. does not collect personal information directly from individuals in the EEA or the United Kingdom. Where 20/20 Software, Inc. receives, stores, or processes personal information from our clients in the EEA or the United Kingdom, we will use and disclose such information in accordance with the notices provided by our clients, only if consistent with the DPF Principles, and the choices made by the individuals to whom such personal information relates. We will endeavor, as much as is practicable, to enable our clients to publish and follow the EU Data Protection Directive (and any relevant UK Directives) on their websites that we host.
20/20 Software, Inc. will enable our clients to offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a 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. 20/20 Software, Inc. will enable our clients to provide individuals with reasonable mechanisms to exercise their choices.
ACCOUNTABILITY FOR ONWARD TRANSFER:
20/20 Software, Inc. does not transfer data to third parties outside of its agents. 20/20 Software, Inc. 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 DPF Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), DPF certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada), or any UK Directives if different from EU GDPR. Where 20/20 Software, Inc. has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, 20/20 Software, Inc. will take reasonable steps to prevent or stop the use or disclosure. 20/20 Software, Inc's accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, 20/20 Software remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless 20/20 Software proves that it is not responsible for the event giving rise to the damage.
Please be aware that 20/20 Software, Inc. may be required to disclose an individual's personal information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
20/20 Software, Inc. will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
DATA INTEGRITY AND PURPOSE LIMITATION:
20/20 Software, Inc. does not use personal information provided by individuals to our clients. When directed by our clients to process such information, 20/20 Software, Inc. will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. 20/20 Software, Inc. will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
ACCESS AND RECOURSE
EU and UK individuals have the right to access their personal information. Upon request, and with consent of our clients, 20/20 Software, Inc. will grant individuals access to personal information that it holds about them. In addition, 20/20 Software, Inc. will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Note that all websites that 20/20 Software, Inc. hosts provide a personal profile page that allows the user to modify their personal information and/or request deletion of their account.
ENFORCEMENT AND LIABILITY:
20/20 Software, Inc. conducts compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that 20/20 Software, Inc. determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
Any questions or concerns regarding the use or disclosure of personal information should first be directed to the owner of the website in question (our Client); or if the question or concern is from our Client, then to 20/20 Software, Inc. at the address given below. 20/20 Software, Inc. will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy.
In compliance with the Data Privacy Framework Principles, 20/20 Software, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Frameworks. European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact 20/20 Software, Inc. by email at email@example.com. For complaints that cannot be resolved between 20/20 Software, Inc. and the complainant, 20/20 Software, Inc. has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the DPF Principles:
Furthermore, in compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, 20/20 Software, Inc commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to BBB NATIONAL PROGRAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers for more information or to file a complaint. The services of BBB NATIONAL PROGRAMS are provided at no cost to you.
If your DPF 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 https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.
LIMITATION ON APPLICATION OF PRINCIPLES:
Adherence by 20/20 Software, Inc. to these DPF Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; (c) to the extent expressly permitted by an applicable law, rule or regulation; and (d) to the extent that 20/20 Software, Inc. has limited or no control over the actions of its Clients regarding use of personal information that they have collected.
Questions or comments regarding this Policy should be submitted to the 20/20 Software, Inc. by mail to:
20/20 Software, Inc.
2001 West Main Street, Suite 270
Stamford, Connecticut 06902
Or by e-mail to: firstname.lastname@example.org