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DM2 Research and Design, Inc. Safe Harbor Policy

DM2 RESEARCH AND DESIGN, INC. respects individual privacy and values the confidence of its customers, employees, business partners and others. Not only does DM2 RESEARCH AND DESIGN, INC. strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This privacy policy applies to all personal information received by DM2 RESEARCH AND DESIGN, INC. whether in electronic, paper or verbal format.

Safe Harbor Privacy Policy Statement

DM2 RESEARCH AND DESIGN, INC. 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. DM2 RESEARCH AND DESIGN, INC. 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 DM2 RESEARCH AND DESIGN, INC. certification, please visit www.export.gov/safeharbor/

Definitions

“Personal Information” or “Information” means information that (1) is transferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

Principles

Notice

DM2 RESEARCH AND DESIGN, INC. shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which DM2 RESEARCH AND DESIGN, INC.   discloses or may disclose that Information. DM2 RESEARCH AND DESIGN, INC. shall provide the individual with the choice and means 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 DM2 RESEARCH AND DESIGN, INC., or as soon as practicable thereafter, and in any event before DM2 RESEARCH AND DESIGN, INC. uses or discloses the Information for a purpose other than for which it was originally collected.

Choice

DM2 RESEARCH AND DESIGN, INC. will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) 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, DM2 RESEARCH AND DESIGN, INC.   will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. DM2 RESEARCH AND DESIGN, INC.   shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

Onward Transfers

Prior to disclosing Personal Information to a third party, DM2 RESEARCH AND DESIGN, INC.   shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. DM2 RESEARCH AND DESIGN, INC. shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.

Data Security

DM2 RESEARCH AND DESIGN, INC. shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. DM2 RESEARCH AND DESIGN, INC. has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. DM2 RESEARCH AND DESIGN, INC. cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity

DM2 RESEARCH AND DESIGN, INC.   shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, DM2 RESEARCH AND DESIGN, INC. shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access

DM2 RESEARCH AND DESIGN, INC. shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

Enforcement

DM2 RESEARCH AND DESIGN, INC.   uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using the International Centre For Dispute Resolution as a third party resolution provider. They can be contacted as follows:

  1. Online: adr.org/safeharbor
  2. Fax: 877-304-8457 (USA) | 212-484-4178 (Outside USA)
  3. Mail:
    International Centre for Dispute Resolution
    Case Filing Services
    120 Broadway, 21st Fl. New York, NY 10271

 

Personal Information Processes

In the course of delivering services to its customers, DM2 RESEARCH AND DESIGN, INC.   processes data, including Personal Information, on behalf of its customers. In this context, DM2 RESEARCH AND DESIGN, INC.  acts as a data processor and does not control the data. DM2 RESEARCH AND DESIGN, INC.  processes Customer Data under the direction of its Customers, and has no direct control or ownership of the personal data it processes. Customers are responsible for complying with any regulations or laws that require providing notice, disclosure and/or obtaining consent prior to transferring the data to Workday or alternative system for processing purposes.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his or her query to the DM2 RESEARCH AND DESIGN, INC.  Customer (the data controller). If the Customer requests DM2 RESEARCH AND DESIGN, INC.  to remove the personal data to comply with data protection regulations, DM2 RESEARCH AND DESIGN, INC.   will respond to their request within 30 business days.

DM2 RESEARCH AND DESIGN, INC. will refer any request for disclosure of personal data by a law enforcement authority to the Customer. DM2 RESEARCH AND DESIGN, INC. may, where it concludes that it is legally obligated to do so, disclose personal data to law enforcement or other government authorities. DM2 RESEARCH AND DESIGN, INC. will notify Customer of such request unless prohibited by law.

Information Subject to Other Policies

DM2 RESEARCH AND DESIGN, INC. is committed to following the Principles for all Personal Information with the scope of the Safe Harbor Agreement. However, certain information is subject to policies of DM2 RESEARCH AND DESIGN, INC. that may differ in some respects from the general policies set forth in this privacy policy.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of Safe Harbor. We will make this policy and any revisions publicly available on our website.

Please contact the following with any questions regarding this policy:

DM2 RESEARCH AND DESIGN, INC.
Attention: Compliance Department
1370 Grand Cayman Dr.

Merritt Island, FL 32952
Phone: 561-346-1096
Email: compliance@DM2Research.com