1. Introduction
  2. Accu-Time Systems, Inc. (collectively, “ATS”, “we”, “our” or “us”) respect your privacy. This Privacy Shield Notice (“Notice”) describes our standards and procedures for handling Personal Information transferred from the European Union (“EU”) to the U.S. in accordance with ATS’s obligations under the EU-U.S. Privacy Shield Framework.

    ATS has subscribed to and will adhere to the EU-U.S. Privacy Shield Framework by adopting and implementing the Privacy Shield Principles (“Principles”). More information about the Privacy Shield can be found at https://www.privacyshield.gov. Our Privacy Shield certification can be found at https://www.privacyshield.gov/list.

    For the purpose of this Notice, “Personal Information” means any data relating to an identified or identifiable individual (“you” or “your”), including, for example, name, address, telephone number, e-mail address; and “process” or “processing” means any operation performed on Personal Information, such as, for example, collection, use, management, or disclosure. This Notice supplements our ATS Privacy Policy and Terms Of Use.

    We obtain and process Personal Information from the EU in different capacities:
    • As a data controller, we collect and process EU Personal Information either directly from you via our publicly available websites, including www.accu-time.com, or in connection with our customer, partner, employee, prospective employeeand vendor relationships.
    • As an agent (as that term is used in the Principles), we obtain and process EU Personal Information on behalf of and under the instructions of our customers in connection with the time and attendance tracking services we provide. In that context, our customers are the data controllers or agents and the roles and responsibilities of the parties for the processing of Personal Information are defined in our agreements with them.

    ATS commits to comply with the Principles with respect to all Personal Information received from the EU in reliance on the Privacy Shield.

  3. Privacy Shield Principles
    1. Notice
    2. ATS’s Privacy Policy and Terms Of Use, in combination with this Notice, describes our privacy practices with respect to Personal Information received from the EU in reliance on the Privacy Shield.

    3. Choice
    4. When providing our services, our customers choose the types of Personal Information we process and the purposes of the processing. An individual may opt-out of such uses of their personal information by contacting us at privacy@accu-time.com

    5. Accountability for Onward Transfer of Personal Information
    6. ATS may transfer Personal Information for the purposes described in the ATS Privacy Policy and Terms Of Use to a third party acting as a service provider. If we intend to disclose Personal Information to a third party acting as a service provider we will comply with, and protect, Personal Information as provided in the Accountability for Onward Transfer Principle. We remain responsible for the processing of Personal Information received under the Privacy Shield and subsequently transferred to a third party acting as a service provider, unless the third party acts against our explicit instructions.

    7. Security
    8. ATS takes reasonable and appropriate precautions, considering the risks involved in the processing and the nature of the Personal Information, to help protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

    9. Data Integrity and Purpose Limitation
    10. Any Personal Information we receive may be used by ATS for the purposes indicated in our ATS Privacy Policy and Terms Of Use or as otherwise defined in our agreements with our customers. We will not process Personal Information in a way that is incompatible with these purposes unless subsequently authorized by you or a customer.

    11. Access
    12. You have reasonable access to your Personal Information that we collected as a data controller and you may request corrections, deletions, or additions where the Personal Information is inaccurate or has been processed in violation of the Principles. We may limit or deny access to such Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Principles. You may request access to your Personal Information by contacting us as described below.

    13. Recourse, Enforcement and Liability
    14. ATS has established procedures to periodically verify implementation of and compliance with the Principles. ATS conducts self-assessments of its practices regarding Personal Information intended to verify that the assertions ATS makes about its practices are true and that such practices have been implemented as represented.

      Please refer to our Privacy Policy and Terms of Use for a complete description of Indemnification & Exclusions, Limitations and Liability.

      ATS is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”). In certain situations, ATS may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

      Individuals may file a complaint with us at privacy@accu-time.com, if they have any complaints with ATS’s processing of their Personal Information under the Privacy Shield Program. If the dispute is unable to be resolved through ATS’s internal processes, ATS offers a variety of options for the individual to resolve their dispute. If the dispute involves data collected in the context of an EU resident’s employment relationship, we will cooperate with competent EU data protection or labor authorities and comply with the advice of such authorities. If those authorities determine that we did not comply with this policy, we will take appropriate steps to address any adverse effects and to promote future compliance. If the dispute involves other types of data, individuals may file a claim with Judicial Arbitration and Mediation Services (JAMS) here: https://www.jamsadr.com/eu-us-privacy-shield. Under certain circumstances, an individual may invoke binding arbitration. Please see the Privacy Shield website: https://www.privacyshield.gov/Program-Overview for more information on conditions giving rise to binding arbitration.

  4. Amendment
  5. This Notice may be amended consistent with the requirements of the EU-U.S. Privacy Shield Framework. When we update this Notice, we will also revise the "Last Updated" date at the bottom of this document.

  6. Contact for Questions or Complaints
  7. If you have any questions, concerns or complaint regarding our privacy practices, or if you’d like to exercise your choices or rights, you can contact us:
    • By email to: privacy@accu-time.com
    • By mail to: Accu-Time Systems, Inc., Attn: [Jean-Pierre Van de Capelle or Lisa Gladysz], 20-B International Drive, Windsor ,CT 06095
    • By email to: privacy@accu-time.com
    • By mail to: Accu-Time Systems, Inc., Attn: [Darren Duggan],C1 Caerphilly Business Park, Caerphilly, CF83 3ED, UK

    Last Updated: October 17, 2018