Certent (“Certent” or the “Company”) collects and uses personal information you provide to the Company through this website solely to directly contact individuals who express interest in receiving our services. The Company does not sell any personal information to any third parties. By providing the Company your personal information, you agree that the Company may contact you and may use, store, process, and disclose to third parties your personal information solely and exclusively for the purpose for which it was originally collected and may not use, store, process, and/or disclose your Personal Information for any other purpose. See Certent’s Privacy Policy below for more information about how Certent protects your privacy.

EU-U.S. Privacy Shield

Certent and its subsidiary company DisclosureNet, Inc participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Certent is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.  To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. (https://www.privacyshield.gov/list)

Certent is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Certent complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Certent is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, Certent may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov], you may invoke binding arbitration when other dispute resolution procedures have been exhausted

 

U.S. – Swiss Safe Harbor Framework

Certent complies with 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 data from Switzerland. Certent 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 Certent certification, please visit  https://safeharbor.export.gov/swisslist.aspx.

 

Definitions

“Personal Information” or “Information” means information that (1) is recorded in any form; (2) is about, or pertains to a specific individual; and (3) can be linked to that individual.

 

Collection

If you are an employee of a company that is a customer (client entity) of Certent, as part of our Software as a Service (SaaS) offerings, we may collect the following personal information from your employer about you such as: First Name, Middle Initial, Last Name, Taxid, Address, Office Phone, Home Phone, Cell Phone, Fax, Email address, Stock Option Grants, Date of Birth, Retirement Eligibility Date, Annual Salary. Not all of these fields are required and hence they may or may not be stored in our database.

 

Principles

Notice

The Personal Information the Company receives comes from use of our web site by individuals and use of our services by employees of a customer company or by administrators on behalf of such employees of a customer company.  The Company uses this Personal Information solely to directly contact individuals who express interest in receiving our services or to provide such services.  The Company does not sell any Personal Information to any third parties.

Company informs customer companies providing their employees’ Personal Information of the purpose for which Company collects and uses the Personal Information and the types of non-agent third parties to which the Company discloses or may disclose that Information. If the individual is providing his or her Personal Information directly, then Company 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 the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which it was originally collected.

If in connection with providing its services, the Company receives Personal Information indirectly through an administrator employee, and not the individual with respect to which the Personal Information is regarding, then the administrator employee has received the express or implied consent of the applicable employee with whose Personal Information is being provided.

 

Choice

The Company will offer individuals providing their Personal Information directly and administrator employees the opportunity to choose (opt out) whether the Personal Information provided by them 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.

By using the Company’s services and providing Personal Information to the Company through such use, individuals or administrators on behalf of those individuals have opted to authorize the Company to use the Personal Information for the purpose it was intended but for no other purpose.

 

Onward Transfers

The Company may provide Personal Information to third parties performing services on the Company’s behalf for the benefit of such individuals whose Personal Information is being disclosed provided that such third parties have agreed in writing with Company that they will provide at least the same level of privacy protection as is required by the Principles.  Other than as permitted in the prior sentence, prior to disclosing Personal Information for any other purpose, Company shall notify the individual or company administrator employee of such disclosure and allow the individual the choice (opt out) of such disclosure. Company 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.

 

Cookies and Related Technologies

This website uses cookies and related technologies. Cookies are small data files that are served by our platform and stored on your device. Our site uses cookies dropped by us or third parties for a variety of purposes including to operate and personalize the website. Also, cookies may be used to track how you use the site to target ads to you on other websites. The types of data collected may include IP addresses, cookies identifiers, or website activity. You can opt out of receiving targeted ads served by us or on our behalf by clicking on the blue icon in the corner of the ads we serve or by clicking here.

Certent and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

We partner with a third party to display advertising on our website or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising, click here (or if located in the European Union click here). Please note you will continue to receive generic ads.

 

Data Security

Company shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Company 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. Company cannot guarantee the security of Information on or transmitted via the Internet.

 

Data Integrity

Company 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.

 

Access

Company shall allow an individual access to their Personal Information. Individuals can request their employer or administrator 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.

Upon request Certent will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging in to your account and contacting us by opening a support ticket or contacting your employer or administrator directly.  We will respond to your request within a reasonable timeframe.

Certent acknowledges that you have the right to access your personal information.  Certent has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the Certent Client Entity (the data controller). If requested to remove data, we will respond within a reasonable timeframe.

 

Enforcement

Company 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 (an independent resource mechanism) as a third party resolution provider.

In certain situations, Certent may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

Amendments

This Privacy Policy may be amended from time to time consistent with the requirements of the Privacy Shield Framework. The Company will post any revised policy on this website. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

 

Information Subject to Other Policies

The Company is committed to following the Principles for all Personal Information within the scope of the Privacy Shield Framework. However, certain information is subject to policies of the Company that may differ in some respects from the general policies set forth in this Privacy Policy.

 

Contact Information

In compliance with the EU-US Privacy Shield and US-Swiss Safe Harbor Principles, the Company commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact the Company at:

 

Certent, Inc.
Attn:  Vasanth Madhure, Director of Technology Operations
4683 Chabot Drive, Suite 260
Pleasanton, CA 94588
Telephone: (925) 730-4300
Fax: (925) 730-4045

The Company has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield and US-Swiss Safe Harbor Principles to an independent recourse mechanism (IRM).  If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov], you may invoke binding arbitration when other dispute resolution procedures have been exhausted

Effective date: March 20, 2011
Last Update: September 29, 2016