Our EEA business activities are primarily in regard to determining whether inquiry subjects are on restricted party screening lists maintained by governmental authorities and other organizations, including among others FBI, Interpol, U.S. Departments of Defense, State and Treasury, the EU, Australia, Canada, England, India, Ireland, Japan, Netherlands, United Nations and the World Bank. Inquiries are most often initiated by companies with which the inquiry subjects wish to engage in business and to which the inquiry subjects have given consents to the inquiries.
With regard to the transfer of personal information from the EU, UK or Switzerland to the United States, CSI relies on the European Commission’s standard contractual clauses (SCC’s) that are currently recognized by the EU, UK and Swiss data protection authorities as an alternative data transfer mechanism and tries to implement technical measures, including encryption, that can prevent U.S., authorities from accessing any such transferred information without legal process. We also comply with the Privacy Shield Frameworks as a way to articulate and illustrate our commitment to data subject privacy and provide individuals with an additional legal recourse method that is enforceable in the United States.
CSI is subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC).
The following principles apply to EU, UK and Swiss personal data as described below while it is in the United States:
In compliance with the Privacy Shield Principles, CSI commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact CSI at: CSI, ATTN: Data Protection Officer, 3901 Technology Drive, Paducah, Kentucky 42001-5201 or emailed to firstname.lastname@example.org.
CSI has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1.
We do not collect any Special Categories of Personal Data (GDPR Article 9) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about your criminal convictions and offences, if any, except to the extent that criminal conduct has resulted in your being listed on a restricted party screening list.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing or other information.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing or other informational messages at any time by contacting us by email at email@example.com.
Where you opt out of receiving these marketing and other informational messages, this will not apply to personal data provided to us as a result of a service or work that we performed for you or other similar transactions.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We are a service company based in the United States and provide various services for companies in the EEA, the UK and Switzerland. To perform our services and comply with our contractual obligations with our clients, we may share your personal data outside the EEA, the UK or Switzerland.
We recognize that many countries globally have regulations restricting the flow of personal data across international borders. We have put in place measures to ensure that adequate protection is provided to such data where legally mandated. Whenever we transfer your personal data out of the EEA, the UK or Switzerland, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one (1) month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Lawful Basis means any of the six (6) bases listed in Article 6.1(a)-(f) of the GDPR, including those reflected in the right column of the Purposes table, above.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
You have the right to make a complaint at any time to the proper authority for data protection issues; however, we would appreciate the chance to deal with your concerns before you approach these authorities.
Communications, queries, complaints or requests to exercise informational rights can be addressed to CSI, ATTN: Data Protection Officer, 3901 Technology Drive, Paducah, Kentucky 42001-5201 or emailed to firstname.lastname@example.org.
Computer Services, Inc. (CSI)
ATTN: Data Protection Officer
3901 Technology Drive
Paducah, Kentucky 42001-5201
Last Reviewed: May 3, 2021