Safe Harbor Privacy Policy
Faria Systems Inc. ("ManageBac") respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. ManageBac strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, and prides itself on upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that ManageBac follows with respect to personal information transferred from the European Union (EU) to the United States.
Safe Harbor
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. Companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. Consistent with its commitment to protect personal privacy, ManageBac adheres to the Safe Harbor Principles.
Scope
This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by ManageBac in the United States from the European Economic Area, in any format including electronic, paper or verbal.
Definitions
For purposes of this Policy, the following definitions shall apply:
"ManageBac" is owned and operated by Faria Systems Inc., a Delaware corporation in the USA.
"Personal information" means any information or set of information that identifies or is used by or on behalf of ManageBac 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.
"Sensitive" means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual's health. In addition, ManageBac will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
Notice
ManageBac enters into service agreements with its clients in the EU which may include the processing and/or storage of information relating to their clients' customers (students, parents and staff). In these agreements, the EU client agrees and recognizes that it is the 'data controller' for the purposes of data protection legislation. This means that our EU clients are responsible for complying with the data protection legislation in the relevant Member State national law before it sends its customer data to ManageBac for processing and/or storage. Any data processed or stored by ManageBac is only disclosed to third parties at the request and direction of its European client as the data controller, or when required by law. Any information that our EU clients identify as sensitive will be treated as such.
ManageBac has a Compliance Manager who is responsible for the internal supervision of ManageBac privacy policies. ManageBac also has technicians to handle data security. ManageBac continuously educates its employees about compliance with the Safe Harbor Principles and has self-assessment procedures in place to ensure its compliance. ManageBac participates in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce.
Information Gathering and Usage:
ManageBac will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Enforcement:
ManageBac will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that ManageBac determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
Dispute Resolution:
ManageBac participates in the European Data Protection Authorities' Safe Harbor dispute resolution process. If you feel that this company is not abiding by its posted privacy policy or is not in compliance with the Safe Harbor principals, you should first contact ManageBac's Compliance Manager by email at privacy@managebac.com. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact the European Data Protection Authorities.
You can contact the European Data Protection Authorities' Safe Harbor Dispute Resolution Program in your member state at: http://ec.europa.eu/justice_home/fsj/privacy/nationalcomm/index_en.htm
Client Data Storage:
ManageBac complies with the EU Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use, and retention of data from the European Union.
If you have any questions, comments, or concerns or wish to update, delete or change any personal information submitted on this Site, or have any questions about our Privacy Policy, please notify us through postal mail at:
ManageBac
Privacy Department
548 Market St. #40438
San Francisco, CA 94104
Changes To This Safe Harbor Privacy Policy
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on ManageBac's web page: http://www.managebac.com.
Effective Date: February 1st, 2010