Privacy Policy

VALGENESIS SAFE HARBOR PRIVACY POLICY STATEMENT

ValGenesis supports the right to privacy, including the rights of individuals to control the dissemination and use of personal data that describes them, their personal choices, or life experiences. In the course if its business, it is necessary for ValGenesis to record, store, process, transmit, and otherwise handle private information about individuals. ValGenesis takes these activities seriously and provides fair, secure, and fully-legal systems for the appropriate handling of this private information. All such activities at ValGenesis are intended to be consistent with both generally accepted privacy ethics and standard business practices.

ValGenesis complies with the U.S.-EU Safe Harbor Framework and 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 information from European Union member countries and Switzerland.  ValGenesis has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement

 

VALGENESIS SAFE HARBOR CERTIFICATION FRAMEWORK

All personal data must be processed fairly and lawfully, according to the laws and regulations of all jurisdictions where ValGenesis does business.

Personal data must be collected for purposes communicated to the individual and not further processed in a way incompatible with those purposes. Further processing of such data for historical, statistical or other business purposes is not incompatible with the original purpose provided the further processing includes adequate additional controls protecting the rights of the individual.

The amount of personal data collected must be adequate, relevant, and not excessive in relation to the purposes for which they are collected or for which they are further processed.

Personal data must be accurate and complete, and where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate or incomplete, keeping in mind the purposes for which it was collected or for which it is further processed, are definitively erased or corrected.

Individuals must be given an opportunity to examine, and issue complaints about, inaccuracies and in-completions in records containing their personal data. Investigations of complaints must be performed promptly, and must be answered with a letter informing the involved individuals about the courses of action that ValGenesis will take. Any resulting erasures or corrections must be performed promptly and at no cost to the individuals. Reasonable steps to prevent reoccurrence of the same inaccuracies or in-completions must also be taken, for instance by adding an explanatory paragraph in the subject’s file. An exception to the requirements stated in this paragraph is permitted for personal data in management succession planning records, criminal activity investigation records, and other legitimate business activities where disclosure to the individual would be highly likely to jeopardize the project underway.

Personal data must not be kept in a form that permits identification of individuals for any longer than is necessary for the purposes for which the data was collected or for which it is further processed. For example, this can be implemented with linked separate files respectively containing identification information and related sensitive information.

Personal data may be processed only if:

  • The individual has given his or her consent unambiguously.
  • Processing is necessary for the performance of a contract to which the individual is party, such as completing an order for goods.
  • Processing is required to respond to a request made by the individual.
  • Processing is necessary for compliance with a legal obligation to which the Owner is subject.
  • Processing is necessary in order to protect the vital interests of the individual.
  • Processing is necessary to explore or provide new business products or services that may be of use to the Owner, as long as these new products or services do not override the fundamental rights or freedoms of the individual.

Processing personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, criminal offenses, health, or sex life is prohibited unless:

  • The individual has provided explicit consent to such processing.
  • Processing is necessary for the purposes of carrying out the obligations and specific rights of the Owner in the field of employment law.
  • Processing is necessary to protect the vital interests of the individual or of another person where the individual is physically or legally incapable of giving his or her consent. Custodians of personal data are responsible for ensuring that items in the preceding two points are complied with.

ValGenesis may provide third parties with personal data processed on its systems for generally accepted business purposes such as court orders, subpoenas, employment verification, governmental licensing, underwriting, and other reasons. All recipients of such information must definitively identify themselves, certify in writing the legal and customary purposes for which the information is sought and certify that the personal data will be used for no other purposes.

ValGenesis constantly implement and upgrade the latest security technologies to ensure the highest protection for all the private data, both while it is being stored and during times of data transfer”

ValGenesis Independent Recourse Mechanism (IRM)

ValGenesis provides independent recourse mechanism under the Safe Harbor Framework .All the complaints are recorded with details. All the recorded complaints are analyzed and resolved. In case the complaint is not resolved the appropriate justification for handling the complaint may be provided. All unresolved complaints will be handled by the American Arbitration Association.

To learn more about the Safe Harbor program, and to view ValGenesis’s certification, please visit http://www.export.gov/safeharbor/

 

x