Last Updated: September 27, 2023
DATA PRIVACY FRAMEWORK
WHO WE ARE
HOW WE COLLECT PERSONAL DATA AND OTHER INFORMATION
TYPES OF PERSONAL DATA COLLECTED
As a controller, ISN obtains Personal Data in other ways. For example, we may collect Personal Data directly from you when you visit our website or use our App. The type of Personal Data we may collect directly from you includes your first and last name, contact information (e.g., email address and mobile number), ISN-ID number, ZIP code, Personal Data you provide to us on the Empower platform (e.g., training certifications or other credentials), and other data collected automatically through our website or App (e.g., when you interact with the App or post or upload information through the App in connection with our Services).
HOW WE USE AND DISCLOSE PERSONAL DATA
We generally will not share your Personal Data with third parties outside the scope of our Services, but in certain instances we may be required to disclose your Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. To the extent permitted to do so, we will endeavor to inform you if we are required to disclose your Personal Data in response to a lawful request to do so. We also reserve the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution, or liquidation).
When we collect Personal Data directly from individuals in the EU, UK, or Switzerland as a controller, we generally offer you the opportunity to choose if your Personal Data may be (i) disclosed to third parties acting as controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant individual.
When we maintain Personal Data about individuals in the EU, UK, or Switzerland for whom we obtained or maintain the Personal Data as a processor, our Hiring Clients, ISNetworld Contractors, and Data Providers are responsible for providing the relevant individuals with certain choices with respect to the Hiring Clients’, Data Providers, and ISNetworld Contractors’ use or disclosure of the Personal Data.
From time to time we may also use your Personal Data to provide you with information about our Services, including updates and changes relating to Empower. You may choose to “opt out” of receiving this type of information at any time by contacting us as provided in Section 9 below.
DATA QUALITY AND ACCESS TO PERSONAL DATA
We strive to provide our Services in the best possible manner, which means it is very important that the information in Empower remains accurate, complete, and up-to-date. As we rely on you, Hiring Clients, ISNetworld Contractors and Data Providers for information, we take steps to ensure that these parties understand the importance of keeping the information they maintain and share through Empower as accurate and current as possible. However, unless we are notified that any of your Personal Data is inaccurate or incomplete, we cannot take steps to correct it. You generally have the right to request access to your Personal Data. When we maintain Personal Data about individuals for whom we obtained or maintain the Personal Data as a processor, the Hiring Clients, ISNetworld Contractors, or Data Providers are responsible for providing you with access to your Personal Data and the right to correct, amend, or delete the information where it is inaccurate or has been processed in violation of the DPF Principles, as appropriate. In such circumstances, you should direct your questions to the appropriate Hiring Client, ISNetworld Contractor, or Data Provider. When you are unable to contact the appropriate Hiring Client, ISNetworld Contractor, or Data Provider, or do not obtain a response from the appropriate Hiring Client, ISNetworld Contractor, or Data Provider, ISN will provide reasonable assistance in forwarding your request to the appropriate Hiring Client, ISNetworld Contractor, or Data Provider.
When we maintain Personal Data as a controller, we provide a reasonable opportunity for individuals in the EU, UK, or Switzerland to correct, amend or delete the information where it is inaccurate or has been processed in violation of the DPF Principles, as appropriate. We may limit or deny access to Personal Data 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 persons other than you would be violated. You may request access to your Personal Data by contacting ISN as indicated below in Section 9. Given the nature of our Services, we may need to retain Personal Data after the end of any particular engagement involving Hiring Clients, ISNetworld Contractors or Data Providers (e.g., to provide a historical audit trail for safety and qualification purposes).
SAFEGUARDING MEASURES AND ACCOUNTABILITY FOR ONWARD TRANSFER
ISN takes reasonable and appropriate measures to help protect your Personal Data from loss, misuse, and unauthorized access, modification, or disclosure, taking into account the risks involved in the processing and the nature of the Personal Data.
CONTACT INFORMATION; DISPUTE RESOLUTION
ISN Software Corporation
3232 McKinney Avenue, Suite 1500, Dallas, Texas 75204
Telephone: +1 214 303 4900 | Email: email@example.com
ISN has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to BBB EU Data Privacy Framework, an alternative dispute resolution provider located in the U.S. and 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 https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint.
In addition, the United States Federal Trade Commission has investigatory and enforcement powers over ISN regarding compliance with the Data Privacy Framework. There is a possibility, under certain conditions, for individuals to invoke binding arbitration to address complaints about ISN’s compliance with the DPF Principles.