Overview
NetLine Corporation. ("NetLine," "we," "us," or "our") complies with the requirements of 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 (the "Principles"). NetLine has certified that it adheres to the Principles with respect to personal information (as described below) that is transferred from the European Union and its Member States, and the European Economic Area and Switzerland ("EU") to the United States. If there is any conflict between the terms in this Privacy Shield Policy and the Principles, the Principles shall govern. NetLine is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.
This Privacy Shield Policy applies to personal information within the scope of NetLine Privacy Shield certification, which covers the personal data in the following categories:
- Personal data of clients, customers, business partners, prospective clients, third party marketing leads, and affiliates related to the identity, role, and background of individuals at various businesses. NetLine collects this information to provide lead generation services to its customers. The personal data collected includes identifying information such as names, addresses, business titles, email address, etc, in order to help our customers identify individuals who have an expressed interest in the customer's business, business sector, or industry. Information collected may be transferred to business partners, NetLine affiliates and third-party service providers performing study related duties and may furthermore be transferred to regulatory authorities;
- Personal data related to prospective marketing targets for customers and users of NetLine applications and websites who make enquiries regarding NetLine products or services and who may be asked to provide personal information in order to provide the requested information, products or services. Personal information provided may be used for the processing of requested transactions, improving the quality of our services, sending communications about our products and services, enabling our business partners and service providers to perform certain activities on our behalf and complying with our legal obligations, policies and procedures.
- NetLine may use the personal information it collects to comply with our legal obligations, policies and procedures and for internal administrative purposes
Individual Notice and Choice
We collect and process personal information from certain individuals and for the purposes described in this Privacy Shield Policy. Personal information covered by this Privacy Shield Policy is collected and processed only as permitted by the Principles.
Notice to individuals regarding the personal information collected from them and how that information is used may be provided through this Privacy Shield Policy, other NetLine website notices, or other direct forms of communication with appropriate parties, such as contracts or agreements. Where necessary and appropriate, consent for personal information to be collected, used, and/or transferred may also be obtained through these same means of communication (including opt-in consent for sensitive personal information).
Disclosures & Accountability for Onward Transfers
Consistent with the Principles, NetLine may transfer personal information to third parties, including transfers from one country to another. We will only disclose an individual's non-public personal information to third parties under one or more of the following conditions:
- The disclosure is to a third party providing services to NetLine, or to the individual, or is in connection with the operation of a clinical trial, and as consistent with the purpose for which the personal information was collected. We maintain written contracts with these third parties and require that these third parties provide at least the same level of privacy protection and security as required by the Privacy Shield Principles. To the extent provided by the Principles, NetLine remains responsible and liable under the Privacy Shield Principles if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield Principles, unless NetLine proves that it is not responsible for the matter giving rise to the damage.
- With the individual's permission to make the disclosure;
- Where required to the extent necessary to meet a legal obligation to which NetLine is subject, including a lawful request by public authorities and national security or law enforcement obligations and applicable law, rule, order, or regulation.
- Where reasonably necessary for compliance or regulatory purposes, or for the establishment of legal claims.
Access
Individuals whose personal information is covered by this Privacy Shield Policy have the right to access the personal information that NetLine maintains about them as specified in the Principles. Individuals may contact us to correct, amend, limit usage of, or delete such personal information if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual's privacy, or where the rights of persons other than the individual would be violated). Requests for access, correction, limitation, amendment or deletion should be sent to:
privacy@NetLine.com.
Security
NetLine takes appropriate measures to protect personal information in its possession to ensure a level of security appropriate to the risk of loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures take into account the nature of the personal information and the risks involved in its processing, as well as best practices in the industry for security and data protection.
Data Integrity and Purpose Limitation
NetLine collects and processes personal information only to the extent that it is compatible with the purposes for which it was collected or subsequently authorized by the data subject. NetLine does not retain personal information it no does not serves the legal, regulatory, or business purposes for which it was collected or subsequently authorized. NetLine takes reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use. In certain circumstances, individuals can request to limit our usage of personal data. To make such a request, please contact us at
privacy@NetLine.com
Enforcement
In compliance with the Principles, NetLine commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact NetLine at:
privacy@NetLine.com. NetLine has a policy of responding to individuals within thirty (30) days of an inquiry or complaint.
If an individual has an unresolved complaint or concern that is not addressed satisfactorily, NetLine agrees to cooperate and comply with the EU data protection authorities (DPAs) and the Swiss Federal Data Protection Information Commissioner (FDPIC) regarding the unresolved complaints of data subjects who are located in the EU and Switzerland. Such individuals may direct complaints about their personal information to their respective DPA. For the contact information for your country's DPA, please contact us at the address given below. NetLine commits to cooperate with DPAs and the FDPIC, and to comply with the advice given by such authorities with regard to non-human resources data transferred from the EU and Switzerland in the context of any relevant employment relationship.
You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website. To learn more about the Privacy Shield Framework, and to view NetLine certification, please visit
https://www.privacyshield.gov.
Modifications
NetLine may update this Policy at any time by publishing an updated version here. We will not update this Privacy Shield Policy in contravention to the Principles so long as we remain certified to the Privacy Shield.
Privacy policy effective: May 15, 2019