MS SHIFT, INC. (“MS SHIFT") has a strong commitment to providing excellent service to our customers, including respecting their concerns about privacy.
Our website does not collect personally identifiable information from your computer when you browse this website and request pages from our servers. We only collect information you choose to submit during your use of this website.
The information we collect is used to improve the content of our Web page, used to customize the content and/or layout of our page for each individual visitor, used to notify consumers about updates to our Web site, used by us to contact consumers for marketing purposes, disclosed when legally required to do so, at the request of governmental authorities conducting an investigation, to verify or enforce compliance with the policies governing our Website and applicable laws or to protect against misuse or unauthorized use of our Website, to a successor entity in connection with a corporate merger, consolidation, sale of assets or other corporate change respecting the Website.
We do not sell, rent, or lease our customer lists to third parties without your prior approval. With respect to Ad Servers: We do not partner with or have special relationships with any ad server companies. Persons who supply us with their telephone numbers or emails on-line will only receive telephone contact from us with information regarding questions or comments they have placed on-line.
If you do not want to receive e-mail from us in the future, please let us know by sending us e-mail at the above address, calling us at the above telephone number, writing to us at the above address.
If you supply us with your postal address on-line you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by.
With respect to security: We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you at our site.
MS SHIFT & the US-EU Privacy Shield
In compliance with the Privacy Shield Principles, MS SHIFT commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Private Shield policy should first contact MS SHIFT at the above address or phone number
MS SHIFT has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.
MS SHIFT, INC. has certified that it adheres to the EU-US Privacy Shield principles:
- Accountability for Onward Transfer
- Data Integrity and Purpose Limitation
- Recourse, Enforcement and Liability
To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/
PRIVACY SHIELD PRINCIPLES
EU Personal Data is processed subject to the Privacy Shield Principles.
. MS SHIFT, INC. informs individuals about the types of personal data collected and, where applicable, the entities or subsidiaries of MS SHIFT, INC. also adhering to these principles. MS SHIFT, INC. informs individuals of the purposes for which it collects and uses information about them, the identities or types of third-parties to which MS SHIFT, INC. discloses the information, the purposes for which MS SHIFT, INC. may disclose and the choices and means MS SHIFT, INC. offers individuals for limiting the use and disclosure of such personal information.
This notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to MS SHIFT, INC. or as soon thereafter as is practicable, but in any event before MS SHIFT, INC. uses such information for a purpose other than that for which it was originally collected or processed by the transferring organization or discloses it for the first time to a Third-Party.
. MS SHIFT, INC. offers individuals the opportunity to choose whether their personal information is: (a) to be disclosed to a Third-Party; or (2) to be used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by the individual. MS SHIFT, INC. provides individuals with clear and conspicuous, readily available, and affordable mechanisms to exercise these choices.
MS SHIFT, INC. will not provide “choice" when disclosure is made to a third party that is acting as an agent to perform task(s) on behalf of and under the instructions of MS SHIFT, INC. MS SHIFT, INC. shall always enter into a contract with such agent to protect the confidentiality and security of your personal data.
MS SHIFT, INC. will obtain the express consent (opt in) from individuals if Sensitive Information is to be: (a) disclosed to a third party; or (b) used for a purpose other than those for which it was originally collected or subsequently authorized by the individuals through the exercise of opt-in choice. MS SHIFT, INC. will treat as sensitive any Personal Information received from a third party that identifies and treats it as sensitive.
ACCOUNTABILITY FOR ONWARD TRANSFER
. To transfer personal data to a third party acting as an agent, MS SHIFT, INC. shall:
- Transfer such personal data only for limited and specified purposes.
- Ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Privacy Shield Principles.
- Take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with MS SHIFT, INC.’s obligations under the Privacy Shield Principles.
- Require the agent to notify MS SHIFT, INC. if the agent determines it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles.
- Upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing.
- Provide a summary or representative copy of the relevant privacy provisions of its contract with that agent to the US Department of Commerce upon request.
To transfer personal data to a third party acting as a controller, MS SHIFT, INC. shall comply with the Notice and Choice principles. MS SHIFT, INC. shall also enter into a contract with the third-party controller. The contract shall provide that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual. It will provide the same level of protection as the Privacy Shield Principles. The contract will require the controller to notify MS SHIFT, INC. if the controller determines it can no longer meet this obligation. The contract shall provide that when such a determination is made the third party controller shall cease processing or take other reasonable and appropriate steps to remediate.
. MS SHIFT, INC. shall take reasonable and appropriate measures to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal data.
DATA INTEGRITY AND PURPOSE LIMITATION
. MS SHIFT, INC. will only process Personal Information in a way that is compatible with the purposes for which it has been collected or subsequently authorized by the individual. MS SHIFT, INC. shall take reasonable steps to ensure that Personal Data is accurate, complete, reliable for its intended use, and current. Personal information shall be retained in a form identifying or making identifiable the individual only for as long as it serves a purpose of processing consistent with the purpose for which it was collected or subsequently authorized by the individual.
. MS SHIFT, INC. provides individuals with access to their personal data for purposes of correcting, amending or deleting that information where it is inaccurate or has been processed in violation of the Principles. Access will not be provided where the burden or expense of providing such access would be disproportionate to the risks to the individual’s privacy or where the rights of persons other than the individual would be violated. A reasonable fee compensating MS SHIFT, INC. for resource use related to accessing, changing or deleting the personal information may be charged.
RECOURSE, ENFORCEMENT AND LIABILITY
. Effective privacy protection includes robust mechanisms for assuring compliance with the Principles, recourse for individuals who are affected by non-compliance with the Principles, and consequences when the Principles are not followed.
. MS SHIFT, INC. has procedures to verify the attestations and assertions it makes about MS SHIFT, INC.’s privacy practices are true and that privacy practices have been implemented as presented. MS SHIFT, INC. verifies compliance with the Principles through self-assessment or outside compliance reviews. Any employee that violates these Principles will be subject to disciplinary procedures in accordance with MS SHIFT, INC.’s disciplinary policy.
Please note that we may be required to disclose your personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
. In compliance with the Privacy Shield Principles, MS SHIFT, INC. commits to resolve complaints about its collection of personal information. Individuals who are affected by or witness non-compliance with these Principles are encouraged to report the matter via MS SHIFT, INC.’s contact details. Alternatively, individuals may contact the US Data Privacy Officer whose direct contact information is:
MS SHIFT, INC.
One World Trade Center
New York, NY 10007
MS SHIFT, INC. will respond to a complaint within 45 days of receipt.
If a complaint cannot be resolved with MS SHIFT, INC. directly, there are readily available independent recourse mechanisms by which individual’s complaints and disputes are investigated and expeditiously resolved at no cost to the individual and by reference to the Principles.
For complaints involving human resource Personal Data of EU citizens, MS SHIFT, INC. commits to cooperate with the panel established by the EU Data Protection Authorities and comply with the advice given by the panel with regards to human resources data transferred from the EU in the context of the employment relationship. Complaints regarding processing of HR personal data pertaining to EU citizens may be reported by the individual to the relevant Data Protection Authority.
All other complaints shall be resolved through alternative dispute resolution. MS SHIFT, INC. has selected the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR/AAA), as the administrator of MS SHIFT, INC.’s independent recourse mechanism for non EU-HR disputes. MS SHIFT, INC. has committed to refer such unresolved Privacy Shield complaints to ICDR/AAA in the United States. You may find more information about dispute resolution and how to file a claim with the ICDR/AAA at http://info.adr.org/safeharbor/
Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. Please visit Annex I for additional information:
. In the context of an onward transfer, MS SHIFT, INC. has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. MS SHIFT, INC. shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles unless MS SHIFT, INC. shows it is not responsible for the event giving rise to the damage.