Purpose

The purpose of this Privacy Policy is to inform our clients, employees, business partners and the general public how we protect and handle private and sensitive information. At Prismonde, we are committed to protecting your privacy through stringent privacy practices and adherence to the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. As of 2023, the DPF Program will replace the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Framework, as well as those before. Prismonde in the U.S., as well as our subsidiaries (collectively “Prismonde”), adheres to the DPF Principles.

Prismonde complies with the EU-U.S. DPF as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Prismonde has certified to the Department of Commerce that it adheres to these DPF Principles. If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov.

Prismonde is fully committed to the proper handling and privacy of the personal information that it collects or uses for all individuals within the European Union, UK, and Switzerland. To protect the individual’s information, Prismonde complies with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF designed by the U.S. Department of Commerce, the European Commission, the UK Government and the Swiss Federal Administration.

Prismonde is under the jurisdiction of the U.S. Federal Trade Commission for investigations and enforcement related to compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Prismonde’s privacy practices comply with the following DPF Principles, as detailed in the sections of this document:

  • Notice
  • Choice
  • Accountability for Onward Transfer
  • Security
  • Data Integrity and Purpose Limitation
  • Access
  • Recourse, Enforcement and Liability

Scope and Applicability

This Privacy Policy applies to all data and information collected by Prismonde that allows for identification of an individual (Personal Information (PI) or Personally Identifiable Information (PII)), including all personal data received from the EU, UK and Switzerland  As used within this Privacy Policy, the term “Personal Information” shall be used to refer to any combination of PI and/or PII. The Personal Information (of either clients or employees) may include but is not limited to names, email addresses, date of birth, social security number, mailing and/or business addresses, telephone and fax numbers and employee identification information.

Adherence to this policy applies to all employees who work for Prismonde.

Policy

The following sections of this Privacy Policy comply with the seven Principles and sixteen Supplemental Principles of the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF where applicable.

Notice

This Privacy Policy applies to all Personal Information collected by Prismonde, including all personal data received from the EU, UK and Switzerland. The Personal Information (of either clients or employees) may include but not be limited to names, email addresses, date of birth, social security number, mailing and/or business addresses, telephone and fax numbers and employee identification information.

Prismonde collects, handles and processes your Personal Information only for business purposes with you and/or your company. If your Personal Information is collected and used, Prismonde will notify you, usually at the time of collection or as soon as possible after the information is collected. Prismonde may disclose your Personal Information to comply with any lawful requests from public authorities, law enforcement, or matters of national security.

Prismonde does not sell or rent your Personal Information to anyone. Prismonde may disclose your Personal Information to third parties for legitimate business purposes. The types of third parties that may be used by Prismonde, and the purposes for disclosing Personal Information, include but are not limited to:

  • Vendors that assist with payroll, benefits and HR support for employees
  • Vendors that supply software as a service (SaaS) for internal communications and sales tracking
  • Credit card companies that have employee credit card information
  • Travel expense vendors who manage employee travel expense information
  • Vendors who provide project support or project management support
  • Vendors who provide analytics services for Prismonde’s client projects
  • Vendors who provide backup or storage services for data

Online Information

When you visit a Prismonde website your web browser software may automatically provide us with information such as the browser name and version, your computer type, operating system and the previous website you visited if you clicked a link to our site from another website. We also automatically determine your internet IP address or your internet service provider’s IP address. Any of this information may be recorded in our system logs or securely collected on our behalf via third-party services. This information will only be used internally in anonymized, aggregate reporting.

You may choose to provide Prismonde with additional Personal Information by completing our online forms. We will inform you of how this Personal Information will be used at the point of collection, and Prismonde will only use such Personal Information as described in this Privacy Policy.

Use of Cookies

Certain parts of our website use cookies to provide a more optimal web experience. A cookie is a small piece of data sent to your web browser and saved on your computer. On subsequent visits to our site, your browser will automatically re-transmit the cookie data to our site. We may use cookies to customize the content shown to you, to provide conveniences to your browsing experience or to track aggregate traffic trends on our site. You are not required to accept and store cookies to browse our websites. However, to access any of our protected websites that require a username and password, you will need to accept and store an authentication-related cookie for the duration of your visit.

Our website contains links to other sites. Prismonde does not share your Personal Information with these sites, nor do we have any control over the privacy policies of those sites. We encourage you to learn about the privacy policies of the companies responsible for those sites.

Employee Information

We collect and use employee information only for business purposes, and our employees’ Personal Information is never sold or rented to third parties. Data may be collected and stored from potential candidates for hire with Prismonde, which includes direct employees and contractors. Employee information, including Personal Information, performance and disciplinary information, health-related information or other sensitive employee information is only accessible by Prismonde employees who have legitimate human resource purposes, and/or a business need to know.

European Union, UK and Swiss employees are notified at the time of their employment how their Personal Information will be used. Prismonde will comply with any investigations from EU, UK or Swiss Authorities, as applicable by law.

You can contact us with any data inquiries, complaints, to gain access to your data or understand how to limit the use and disclosure of your data by emailing info@prismonde.com.

Additional details on individual data rights are listed below and can be found further along in this policy.

  • Independent dispute resolution bodies
  • Investigatory and enforcement powers
  • Invoking binding arbitration
  • Requirements to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements
  • Our liability in cases of onward transfers to third parties
  • Third parties we share your data with

Choice

Prismonde will provide you with the opportunity to opt out of having your Personal Information (1) disclosed to a third party who is not currently working for Prismonde, and (2) used for a purpose that is different from the original use or purpose when it was collected or authorized for use by you. The only exception to this choice is the requirement of disclosure of Personal Information by government or judicial order, or other legal requirements.

You can choose to opt out of marketing materials from Prismonde at any time. To exercise your rights to limit how your data is used as described above, contact us at info@prismonde.com with instructions on which opt-out options you would like applied to your Personal Information. Prismonde system administrators will manually apply the appropriate control measures to any records that contain your Personal Information.

Under the DPF Program, organizations do not have to obtain express consent (opt-in) with respect to sensitive data (including Personal Information) under the following processing conditions – If the data processing is in the vital interest of the data subject or another person, if it is necessary for the establishment of legal claims or defenses, if it is required to provide medical care or diagnosis, if the data processing is carried out in the course of legitimate activities by a foundation, association or any other non-profit body with a political, philosophical, religious or trade-union aim and on condition that the processing relates solely to the members of the body or to the persons who have regular contact with it in connection with its purposes and that the data are not disclosed to a third party without the consent of the data subjects, if it is necessary to carry out an organization’s obligations in the field of employment law, or if it is related to data that has been made public by the individual.

Accountability for Onward Transfer of Personal Data

Prismonde will not transfer Personal Information originating in the EU, UK or Switzerland to third parties unless such third parties have entered into an agreement in writing that requires them to provide at least the same level of privacy protection to Personal Information as required by the Principles of the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.. Prismonde only transfers data to agents or third-party service providers who have a legitimate need to the information in order to provide services on behalf of Prismonde. Prismonde will be liable for these data transfers to third parties.

Security

Prismonde is committed to protecting the Personal Information that it collects and stores, and we have implemented technical, operational, and administrative security measures to prevent the loss, misuse, disclosure, alteration, theft, or destruction of such information.

Data Integrity and Purpose Limitation

Prismonde only collects and retains Personal Information that is relevant to the purposes for which it is collected. Personal Information will not be used in a way that is incompatible with such purposes unless such use has been explicitly authorized by you. Prismonde will take reasonable steps to preserve the integrity of your Personal Information and to ensure that it is reliable for its intended use, accurate, complete, and current. Prismonde may contact you to verify that the data we have is accurate and current.

This obligation does not prevent Prismonde from processing Personal Information for longer periods for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research, and statistical analysis.  In these cases, such processing shall be subject to the other principles and provisions of the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Access

You have the right to access and correct your Personal Information that is used by Prismonde. You can correct, amend, or request that information be deleted if it is inaccurate or has been processed in violation of the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

The only exception to an access request for Personal Information is where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of other persons would be violated. To confirm that Prismonde has Personal Information relating to you, or to make any other access or correction requests, contact us at info@prismonde.com. Prismonde employees may request and review their Personal Information by emailing info@prismonde.com.

Recourse, Enforcement and Liability

If you have any questions or concerns about Prismonde's compliance with our Privacy Policy or the DPF, please contact us at info@prismonde.com. We will investigate your complaint thoroughly and will respond to you within 45 days from the time we were notified.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Prismonde commits to resolve complaints about our collection or use of your Personal Information. EU, UK, and Swiss individuals with inquiries or complaints regarding our DPF policy should first contact Prismonde at: info@prismonde.com

If you are not satisfied with Prismonde's response to your complaint, we will provide an additional recourse mechanism at no cost to you.

Prismonde cooperates and complies with the EU data protection authorities (DPAs) under the EU-U.S. DPF, the Swiss-U.S. DPF, the UK ICO under the UK Extension to the EU-U.S. DPF under the UK Information Commissioner’s Office (ICO) and the EU-U.S. DPF and the Swiss-U.S. under the Swiss Federal Data Protection and Information Commissioner (FDPIC) and complies with the advice given by such authorities with regard to human resources and non-human resources data transferred from the EU, UK and Switzerland.

Contact information for the EU DPA, UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection Information Commissioner are as follows:

European Data Protection Supervisor

Rue Wiertz 60
1047 Bruxelles/Brussel
Office: Rue Montoyer 63, 6th floor
Tel. +32 2 283 19 00
Fax +32 2 283 19 50
e-mail: edps@edps.europa.eu
Website: http://www.edps.europa.eu/EDPSWEB/

UK Information Commissioner’s Office (ICO)

Wycliffe House
Water Lane, Wilmslow
Cheshire, SK9 5AF, England12.
Tel. +0303 123 111312
Fax +01625 5245102
Website: https://ico.org.uk/

Swiss Federal Data Protection and Information Commissioner

Verantwortliche Person Adrian Lobsiger
Adresse Feldeggweg 1, 3003 Bern
Telefonnummer +41 (0)58 462 43 95 (Mo. bis Fr., 10.00 bis 12.00 Uhr)
Email-Adresse Kontaktformular
Webseite www.edoeb.admin.ch

Additional lists of more specific DPAs by country, city or region can be found here – http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm and here –https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html.

Under certain conditions, if you are not satisfied with the recourse mechanisms provided by Prismonde or Prismonde's compliance with the DPF, you may be able to invoke binding arbitration to address your complaint.

Right to Change Policy

Any changes to the EU-U.S. DPF and the Swiss-U.S. DPF, or the addition of new or updated applicable laws will result in changes to this Privacy Policy. Prismonde reserves the right to amend this Privacy Policy and its related business procedures at any time.

Prismonde Employee Policy Adherence and Enforcement

It is the responsibility of all Prismonde employees to read and adhere to this Privacy Policy, and by signing this Privacy Policy, each employee agrees to abide by its contents. Any employee found to have violated this Privacy Policy may be subject to disciplinary action, up to and including termination of employment.