Data Privacy Framework Policy

Effective: 2019 Feb 7

Updated: 2023 Aug 30

Join It, Inc ("Join It") complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Join It has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.  Join It has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit the website.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, Join It commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, Join It commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Join It at the email address: security@joinit.com and with the subject line “Data Privacy Framework Request”

I. Scope

This Policy applies to the processing of Individual Customer Personal Data that Join It receives in the United States concerning Individual Customers who reside in the European Union, EEA, and Switzerland. Join It provides products and services to businesses and consumers.

This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)

II. Responsibilities and Management

Join It has designated the Operations Department to oversee its information security program, including its compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). The Operations Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to security@joinit.com.

Join It will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. Join It personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that Join It has undertaken to protect Personal Data.

III. Renewal / Verification

Join It will renew its EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.

Prior to the recertification, Join It will conduct an in-house verification to ensure that its attestations and assertions about its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, Join It will undertake the following:

• Review this Data Privacy Framework policy and its publicly posted website privacy policy to ensure that these policies accurately describe the practices regarding the collection of Individual Customer Personal Data
• Ensure that the publicly posted privacy policy informs Individual Customers of Join It's participation in the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) programs and where to obtain a copy of additional information (e.g., a copy of this Policy)
• Ensure that this Policy continues to comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) principles
• Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (Join It may do so through its publicly posted website, Individual Customer contract, or both)
• Review its processes and procedures for training Employees about Join It's participation in the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) programs and the appropriate handling of Individual's Personal Data
• Join It will prepare an internal verification statement on an annual basis.

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IV. Collection and Use of Personal Data

Join It provides various solutions to its Individual Customers who purchase its products. Join It collects Personal Data from Individual Customers when they purchase its products, register with our website, log-in to their account, complete surveys, request information or otherwise communicate with us. For example, Join It individual customers may choose to seek live support or post to a feedback board.

The Personal Data that we collect may vary based on the Individual Customer's interaction with our website and request for our services. As a general matter, Join It collects the following types of Personal Data from its Individual Customers: contact information, including, a contact person's name, work email address, work mailing address, work telephone number, title, and company name. Individual customers have the option to log into their accounts online and to request service online, including through a live support option; we will collect informationthat they choose to provide to us through these portals.

When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.

The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer.

For certain products, Join It serves as a service provider. In our capacity as a service provider, we will receive, store, and/or process Personal Data. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of our partners and/or agents. The information that we collect from our Individual Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Individual Customer, and as otherwise requested by our partner and/or agent.

Join It uses Personal Data that it collects directly from its Individual Customers and for its partners indirectly in its role as a service provider for the following business purposes, withoutlimitation:

• maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (includingmanaging transactions, reporting, invoices, renewals, and other operations related to providing services to a Individual Customer);
• satisfying governmental reporting, tax, and other requirements (e.g., import/export);
• storing and processing data, including Personal Data, in computer databases and servers located in the United States;
• verifying identity (e.g., for online access to accounts);
• as requested by the Individual Customer;
• for other business-related purposes permitted or required under applicable local law and regulation;
• and as otherwise required by law.

Join It does not disclose personal information to third parties for purposes that are materially different than what it was originally collected for. Should this change in the future, we will provide individuals with the option to opt-out.

V. Disclosures / Onward Transfer of Personal Data

Except as otherwise provided herein, Join It discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.

Join It may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, Join It may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by Join It and they must either:

• comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) principles or another mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of Personal Data;
• or agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy;

Join It also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that Join It may be required to disclose an individual's personal information in response to a lawful request bypublic authorities, including to meet national security or law enforcement requirements. Join It is liable for appropriate onward transfers of personal data to third parties.

VI. Sensitive Data

Join It does not collect Sensitive Data from its Individual Customers.

VII. Data Integrity And Security

Join It uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Join It has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to Join It's electronic information systems requires user authentication via password or similar means. Join It also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.

Further, Join It uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.

VIII. Notification

Join It notifies Individual Customers about its adherence to the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) principles through its publicly posted website privacy policy, available here, and take individual customers approval and adherence to the current policy when they provide their information to us in the transactional process.

IX. Accessing Personal Data

Join It personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.

X. Right To Access, Change, or Delete Personal Data

Right to Access. Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which Join It collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and Join It policies. Upon reasonable request and as required by the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) principles, Join It allows Individual Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by logging into their account profile or by contacting Join It by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to Join It’s support team: support@joinit.com

Requests for Personal Data. Join It will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If Join It receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, Join It will refer such Data Subject to the Individual Customer.

Satisfying Requests for Access, Modifications, and Corrections. Join It will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

XI. Government Oversight, Disclosure, and Accountability

Join It recognizes its responsibility to adhere to the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) Principles while being subject to oversight and enforcement by the Federal Trade Commission (FTC).

I. Federal Trade Commission (FTC) Oversight: Join It acknowledge the FTC's authority to monitor and enforce our compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) Principles, reinforcing our commitment to data privacy.

II. Lawful Requests by public authorities, including to meet national security or law enforcement requirements: Join It acknowledges that in some situations, we may be legally obligated to disclose personal information in response to valid requests from public authorities. This includes cases involving national security or law enforcement requirements. Such disclosures will be conducted with due process and in accordance with relevant laws.

While we strive to protect your personal information, certain legal requirements might necessitate disclosures. We will make reasonable efforts to notify you about such disclosures, unless prohibited by law. Our commitment to safeguarding your data remains steadfast, and we will only disclose information when mandated by lawful processes.

XII. Changes to this Policy

This Policy may be amended from time to time, consistent with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.

XIII. Questions or Complaints

EU, EEA, and Swiss Individual customers may contact Join It with questions or complaints concerning this Policy at the following address: security@joinit.com

XIV. Enforcements and Dispute Resolution

In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) Principles, Join It commits to resolve complaints about your privacy and our collection or use of your personal information. EU, EEA, and Swiss individuals with questions or concerns about the use of their Personal Data shouldcontact us at: support@joinit.com

If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by Join It, EU and Swiss individuals may bring a complaint before the EU Data Protection Authorities (DPAs) and Swiss Federal Data Protection and Information Commissioner (FDPIC).  Finally, as a last resort and in limited situations, EU, EEA and Swissindividuals may seek redress through a binding arbitration mechanism described in Annex I of the Data Privacy Framework Principles.