We may collect the following types of information:
Information Our Clients and visitors provide – When Our Clients and visitors logon to the FinClock EMS, we may ask Our Clients and visitors for personal information, specifically:
We may combine the information Our Clients and visitors submit under Our Clients and visitors account with information from other FinClock EMS services or third parties in order to provide Our Clients and visitors with a better experience and to improve the quality of our services. We may also provide visitors to our System(s) the opportunity to receive communications such as our regular newsletter, product promotions and any other information that we feel may be pertinent to the visitor. Our Clients and visitors may opt for receiving these communications by emailing us at [email protected], by replying to any email we send Our Clients and visitors or by visiting certain locations on our System(s).
Log information – When Our Clients and visitors access FinClock EMS solutions via a browser, application or other client our servers automatically record certain information. These server logs may include information such as Our Clients and visitors’ web request, Our Clients and visitor’s interaction with our systems, Internet Protocol address, browser type, browser language, the date and time of Our Clients and visitors request and one or more cookies that may uniquely identify Our Clients and visitor’s browser or Our Clients and visitors account.
Client communications – When Our Clients and visitors send email or other communications to FinClock EMS, we may retain those communications in order to process Our Clients and visitors inquiries, respond to Our Clients and visitors requests and improve our solutions and services. We may use Our Clients and visitors email address to communicate with Our Clients and visitors about our solutions and services.
FinClock EMS only shares personal and client information with other companies or individuals in the following limited circumstances:
We have Our Clients and visitors consent. We require opt-in consent for the sharing of any sensitive personal information.
We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of FinClock EMS, its clients as required or permitted by law.
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.
We restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
Accessing and updating personal information
When Our Clients and visitors use the FinClock EMS System(s), we make good faith efforts to provide Our Clients and visitors with access to Our Clients and visitors personal information and either to correct this data if it is inaccurate or to delete such data at Our Clients and visitors request if it is not otherwise required to be retained by law or for legitimate business purposes. We may ask individual clients to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.
EU-US and Swiss-US Privacy Shield Compliance
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, FinClock EMS is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to Our Clients and visitors in the United States. Upon request, we will provide Our Clients and visitors with access to the personal information that we hold about Our Clients and visitors. Our Clients and visitors may also correct, amend, or delete the personal information we hold about Our Clients and visitors. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share Our Clients and visitor’s data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of Our Clients and visitors personal information, please submit a written request to [email protected]
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
FinClock EMS has accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party, as described in the Privacy Shield Principles. In particular, FinClock EMS remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless FinClock EMS proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, FinClock EMS commits to resolve complaints about Our Clients and visitors privacy and our collection or use of Our Clients and visitors personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact FinClock EMS at: 202-956- 4726
FinClock EMS has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If Our Clients and visitors do not receive timely acknowledgment of Our Clients and visitors complaint, or if Our Clients and visitors complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to Our Clients and visitors.
If Our Clients and visitors complaint involves human resources data transferred to the United States from the EU and/or Switzerland in the context of the employment relationship, and FinClock EMS does not address it satisfactorily, FinClock EMS commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and to comply with the advice given by the DPA panel and/or Commissioner, as applicable with regard to such human resources data. To pursue an unresolved human resources complaint, Our Clients and visitors should contact the state or national data protection or labor authority in the appropriate jurisdiction. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD.
If Our Clients and visitors Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, Our Clients and visitors may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction