ComSim and Datawise Services Privacy Shield Statement

ComSim, Inc. and Datawise Services, Inc. are full-service market research firms that provide timely and accurate customer knowledge for intelligent business and make a process that is complicated simple.  ComSim and Datawise Services were founded on two overriding beliefs:  the importance of business-to-business customer intelligence to the success of companies in technology and their need to make the complex task of gathering and organizing such data simple.

To fulfill this mission for corporate clients, ComSim and Datawise Services conduct interviews with our clients’ business customers around the globe.  ComSim and Datawise Services receive customer data from our clients, gathers additional data regarding their existing customers’ experience through telephone and web-based surveys, organizes these data into reports and provides them to our clients.    We pledge that when collecting personal information in conjunction with customer research, that it will be used solely for that purpose.  As a member of the Marketing Research Association, ComSim and Datawise Services abide by the legal and ethical standards for market research professionals.

In accordance with the principle that customer satisfaction is essential to its success, ComSim and Datawise Services build enduring client relationships.  ComSim and Datawise Services’ client relationships extend into the European Union nations and Switzerland.

In order to confirm our compliance with the regulations of the EU and Switzerland that serve to protect individuals with respect to the “controlling” and “processing” of personal information as well as to ensure the free movement of personal information within the EU and Switzerland through the coordination of national laws, we have implemented a formal privacy policy statement.

EU-US AND SWISS-US PRIVACY SHIELD

ComSim and Datawise Services comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively.  ComSim and Datawise Services have certified that they adhere to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view ComSim and Datawise Services’ certification, please visit https://www.privacyshield.gov/.

ComSim and Datawise Services are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

In compliance with the EU-US and Swiss-US Privacy Shield, ComSim and Datawise Services commit to resolve complaints about your privacy and our collection or use of your personal information.  European Union or Swiss  individuals with inquiries or complaints regarding this privacy policy should first contact ComSim and Datawise Services by mail, telephone, fax or email to:

ComSim and Datawise Services, Inc.
2465 Black Rock Turnpike
Fairfield, CT 06825
203-336-3360
203-336-3356 (fax)
info@ComSim.com

ComSim and Datawise Services have further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield 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 by ComSim and Datawise Services, please visit the BBB EU PRIVACY SHIELD website at www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

The Information that ComSim and Datawise Services Receive

ComSim and Datawise Services receive data from our clients with which we have a contractual relationship; data to be used in conducting survey activity on behalf of our clients.  These data are defined as “Personal Data” or “Personal Information”:  data transferred to the U.S. from the European Union (EU) and Switzerland about or related to an identified or identifiable individual and that can be linked to that individual and that are recorded in any form.  This privacy statement applies only to personal data that ComSim and Datawise Services receive from the EU and Switzerland.

ComSim and Datawise Services as “Data Processor”

ComSim and Datawise Services act as a “Data Processor” and each ComSim and Datawise Services client act as a “Data Controller.”  An entity defined as a “Data Processor” carries out an operation or set of operations on Personal Data, such as collecting, recording, storing, disclosing or organizing.  A “Data Controller” determines the purposes for which the personal data are processed.   As a Data Processor, ComSim and Datawise Services will process personal data only pursuant to the instructions of the client and provide results solely to the client that commissioned the study.  ComSim and Datawise Services will not share or use such data for our own marketing purposes.

In the course of our business, ComSim and Datawise Services receive from and/or collects on behalf of our clients’ data that may include, among other things, an individual’s name, address, phone number, email address, title, business account or transaction number, ratings and verbatim comments.  All ComSim and Datawise Services employees and contracted agents of ComSim and Datawise Services with access to such personal data are required to read and comply with the ComSim and Datawise Services privacy policy.  ComSim and Datawise Services does not receive, collect or process “sensitive personal data,” such as data that indicate a medical or health condition, political opinion, religion, race or ethnic origin, sexual orientation or alleged or actual criminal activity.  ComSim and Datawise Services does not receive, collect or process human resource data in the context of the employment relationship.

Adherence to Privacy Shield Privacy Principles

ComSim and Datawise Services adhere to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability.

Notice

ComSim and Datawise Services will 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.

In the introduction or invitation to the survey, prospective respondents are adequately informed as to who is conducting the survey and how the information will be used.  Prospective respondents are invited to agree to participate on a voluntary basis.

Choice

In ComSim and Datawise Services’ survey process, all questionnaires for use with respondents in EU and Swiss nations provide the option for their identifying information to be removed.  In telephone surveys permission to proceed with the questionnaire is requested by the interviewer and participation is understood by the prospective respondent to be voluntary.  When email invitations are sent to prospective respondents ComSim and Datawise Services are fully identified as the requester of information and an “opt out” message is included.  If survey respondents elect to be anonymous, their identifying data are removed.

Accountability for Onward Transfer

ComSim and Datawise Services does not disclose to unaffiliated third parties’ data from respondents without permission of the individual to make the disclosure unless disclosure is required by law, the disclosure is reasonably related to the sale of ComSim and Datawise Services’ business, the information is in the public domain, and/or the disclosure is necessary for the establishment of a legal claim. Please be aware that ComSim and Datawise Services 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. ComSim and Datawise Services may transfer personal data to a third party such as translation services, contracted as an agent of ComSim and Datawise Services, provided the contractor has read and agreed in writing to comply with ComSim and Datawise Services’ Privacy Shield Policy and subscribed to the Principles.  In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, ComSim and Datawise Services are liable for appropriate onward transfers of personal data to third parties.

Access

Upon specific request, ComSim and Datawise Services will permit respondents access to any personal data submitted as part of our survey process in order to correct, amend or delete inaccurate information.  An individual requesting access may need to provide identifiable information including, but not limited to, name, company, phone number and/or email address.  Such access may be limited or denied by ComSim and Datawise Services if providing such access would be disproportionate to the risks to the individual’s privacy, overly burdensome, time consuming, would result in significant and/or unreasonable cost to ComSim and Datawise Services, and/or where the rights of persons other than the individual would be violated.

Security

Reasonable precautions are taken by ComSim and Datawise Services to protect personal data against loss, misuse and unauthorized access, disclosure, alteration and destruction.  These precautions include, but are not limited to, password protected data files and websites, data back-up, and secure data servers.

Data Integrity and Purpose Limitation

ComSim and Datawise Services take reasonable steps to ensure that data are reliable for their intended use, as well as accurate, complete and current.   Data processed by ComSim and Datawise Services are solely those relevant for the purposes for which they are supplied / collected and to be used.

As stated in the Privacy Shield Statement, ComSim and Datawise Services confirm to all Privacy Principles required by the EU and Switzerland.  ComSim and Datawise Services’ Research Administrator is responsible for the internal supervision of ComSim and Datawise Services’ privacy policies and their ongoing administration. ComSim and Datawise Services conduct regular self-assessment reviews to ensure full compliance with the Principles.  Any reported violations and follow-up actions to address and/or resolve problems or complaints are contained in an assessment document.  Self-assessment documents are signed by a ComSim and Datawise Services corporate officer and available upon request by an individual or in the context of an investigation or complaint about non-compliance