EU-US and Swiss-US Privacy Shield Compliance
The United States Federal Trade Commission (FTC) is the enforcement authority with jurisdiction over this compliance with the Privacy Shield.
These are our promises to you:
- Notice. We'll give you timely and appropriate notice describing any personal information we're collecting, how we'll use it, and the types of third parties with whom we may share it.
- Choice/Opt-out. We'll give you choices about the ways we use and share your personal information, and we'll respect the choices you make.
gOE will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent 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. To do this you may email us at .
Some communications (e.g. important account notifications) are considered transactional and are necessary for all gOE customers. These communications cannot be opted-out from while you maintain an account with us.
- Accountability for Onward Transfers (to Third Parties). If we transfer your personal information, we'll take appropriate measures to protect your privacy and the personal information we transfer. The Group for Organizational Effectiveness, Inc. is liable for appropriate onward transfers of personal data to third parties.
Should we need to transfer your personal information we will obtain assurances from the third parties that they will safeguard your personal information consistent with this Policy. If we learn that an agent is using or disclosing personal information in a manner that is contrary to this Policy, we will take reasonable steps to prevent or stop it.
Links: As a convenience to our visitors, our Websites may contain links to other sites that we believe may contain useful information. The policies and procedures we described here do not apply to those sites. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies.
Please be aware that The Group for Organizational Effectiveness, Inc. may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
- Security. We'll take appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction. These measures will be appropriate to the risks involved and the nature of the personal data. We know that this is important to you and it is also important to us.
- Data integrity and Purpose Limitation. We'll take appropriate steps to make sure the personal information in our records is accurate and relevant.
We will collect only as much of Your Information as we need for specific, identified purposes, and we won't use it for other purposes without obtaining your consent. We will correct any personal information inaccuracies that you report to us.
- Access. Under the Privacy Shield principles, you have the right and option to review and correct any of Your Information that is inaccurate. We'll provide ways for you to access your personal information, as required by law, so you can correct inaccuracies. To do so, please contact us at . The Group for Organizational Effectiveness, Inc. may restrict access to personal data in exceptional circumstances where the legitimate rights of other persons would be violated or where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy or where access could reveal confidential commercial information.
- Recourse, Enforcement and Liability
The Group for Organizational Effectiveness, Inc. has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Information That We Collect
Communications with Us: When you send an email or submit a web contact form, including support requests for our Services, we may collect the personal information that you provide us and may use it in order to process your inquiries, respond to your requests and improve our Services. These contact forms require users to give contact information (such as name and email address). We use this contact information to send information about our products and services and/or to provide customer service.
Account Information: When you register for a Service, we may ask for and save personal information such as your name, address, phone number and e-mail address. A third-party intermediary is used to manage credit card processing where applicable. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.
By voluntarily providing us with Account Information, you hereby represent that you are the owner of such personal information or are otherwise authorized to provide it to us.
Cookies/Tracking Technologies: Our websites may use a technology called a "cookie." A cookie is a piece of information that our webserver sends to your computer (actually to your browser file) when you access a website. Then when you return to our site, it will detect whether you have one of our cookies on your computer. Our cookies may help provide additional functionality to the site and help us analyze site usage more accurately. For instance, our site may set a cookie on your browser that keeps you from needing to re-enter a password more than once during a visit to the site.
Our sites may use a technology known as web beacons - sometimes called single-pixel gifs - that allow a site to collect web log information. A web beacon is a graphic on a web page or in an e-mail message designed to track pages viewed or messages opened. Web log information is gathered when you visit one of our websites by the computer that hosts our website (called a "webserver"). The webserver automatically recognizes some non-personal information, such as the date and time you visited our site, the pages you visited, the website you came from, the type of browser you are using (e.g., Internet Explorer), the type of operating system you are using (e.g., Windows), and the domain name and address of your Internet service provider. We may also include web beacons in promotional e-mail messages in order to determine whether messages have been opened.
Our websites may use Internet Protocol (IP) Addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet. Generally, an IP address changes each time you connect to the Internet (it is a "dynamic" address). Note, however, that if you have a broadband connection, depending on your individual circumstance, it is possible that your IP Address that we collect, or even perhaps a cookie we use, may contain information that could be deemed identifiable. This is because with some broadband connections your IP Address doesn't change (it is "static") and could be associated with your personal computer. We use your IP address to report aggregate information on use and to help improve the website.
Log Files: As is true with most websites and services, our servers gather certain information automatically and store it in log files. This information includes IP addresses, browser, referring/exit pages, operating system and click stream data as well as certain personal information such as user name, user email address and other information that may be included in open textual fields. Our application log files are subject to the same strict data security policies and procedures as apply to the application databases for our Services. We may combine this automatically collected log information with other information we collect about you. We do this to improve the Services that we offer you, to improve analytics or Website functionality.
Social Media Integrations: Our Websites may include social media features, such as the Facebook Like button, and “widgets”, such as the Share This button. Use of these features is optional. These features may collect your Internet protocol address, which page you are visiting on our Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party and your interactions with these features are governed by the privacy statement of the company providing it.
Finally, as a last resort and in limited situations, individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
We'll regularly review how we're meeting these privacy promises. The Group for Organizational Effectiveness, Inc. assesses annually that it’s policies comply with the Privacy Shield Principles and we have procedures for training employees about our obligations.
Last updated: December 4, 2017