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Authentify European Safe Harbor Policy

Authentify, Inc. (Authentify) is committed to ensuring the security of all data entrusted to us by our clients. Keeping with a tradition of upholding the highest ethical standards and respect for the privacy of our clients, Authentify has certified to the Safe Harbor Agreement between the United States and the European Union. This Safe Harbor Policy adheres to the global privacy principles Authentify follows with respect to Personally Identifiable Information, including transfers from the European Economic Areas (EEA) to the United States.

“Personally Identifiable Information” shall mean any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

Notice
Authentify will inform individuals about the purposes for which it collects and uses Personally Identifiable Information obtained from them, the types of non-agent third parties to which Authentify discloses that information, and the choices and means, if any, Authentify offers individuals for limiting the use and disclosure of their Personally Identifiable Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personally Identifiable Information to Authentify, or as soon as possible thereafter, and in any event before Authentify uses the information for a purpose other than that for which it was originally collected.

Choice
Authentify will offer an individual the opportunity to choose (opt out) whether Personally Identifiable Information obtained from them is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For sensitive Personally Identifiable Information, Authentify will give individuals the opportunity to affirmatively and explicitly (opt in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Onward Transfer
Authentify will only transfer personal data obtained from an individual to a non-agent third party where consistent with the notice provided to the individuals who are the subject of the data and any consent that those individuals have given.

Security
Authentify will take reasonable precautions to protect Personally Identifiable Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Authentify limits access to Personally Identifiable Information to those persons in the Authentify organization, or agents of Authentify, that have a specific business purpose for maintaining and processing such information. Individuals who have been granted access to Personally Identifiable Information are aware of their responsibilities to protect the security, confidentiality and integrity of that information.

Data Integrity
Authentify will use Personally Identifiable Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Authentify will take reasonable steps to ensure that Personally Identifiable Information is relevant to its intended use, accurate, complete, and current.

Access
Upon request, Authentify will grant individuals reasonable access to personal information that it holds about them. Authentify will also take reasonable steps to correct, amend, or delete that information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy in the case in question, or where the rights of persons other than the individual would be violated.

Enforcement
Individuals who wish to file a complaint regarding Authentify’s handling of personal data in accordance with this policy should contact Authentify in writing at its corporate headquarters.

Authentify, Inc.
Attn: Safe Harbor Enforcement
8745 W. Higgins Road, Suite 240
Chicago, IL 60631
USA

Filing the complaint in English will expedite the response. Authentify will review all complaints received to verify that the handling of personal data was consistent with this policy. If Authentify determines that any actions taken were not consistent with this policy, Authentify will immediately take action to remedy any resulting issues. If Authentify is unable to resolve the situation to the satisfaction of the individual concerned, Authentify agrees to mediate the issue through the American Arbitration Association.