ComSim and Datawise Services Data Privacy Policy
ComSim, Inc. and Datawise Services, Inc. are full-service market research firms that provide timely and accurate customer knowledge for intelligent business and make a process that is complicated simple. ComSim and Datawise Services were founded on two overriding beliefs: the importance of business-to-business customer intelligence to the success of companies in technology and their need to make the complex task of gathering and organizing such data simple.
To fulfil this mission for corporate clients, ComSim and Datawise Services conduct interviews with our clients’ business customers around the globe. ComSim and Datawise Services receive customer data from our clients, gathers additional data regarding their existing customers’ experience through telephone and web-based surveys, organizes these data into reports and provides them to our clients. We pledge that when collecting personal information in conjunction with customer research, that it will be used solely for that purpose. As a member of the Marketing Research Association, ComSim and Datawise Services abide by the legal and ethical standards for market research professionals.
In accordance with the principle that customer satisfaction is essential to its success, ComSim and Datawise Services build enduring client relationships. ComSim and Datawise Services’ client relationships extend into the European Union nations, and Switzerland.
Datawise respects your privacy and is committed to protecting your personal information. We comply with the principles of the Data Protection Act 1998 as amended or replaced and the EU Regulation 2016/679 General Data Protection Regulation (“GDPR”). Our aim is to maintain consistently high levels of best practice in our processing of your personal information. This Privacy Policy relates to our use of any personal information you provide to us through the Datawise Group and/or other services provided by Datawise or any company in the Datawise Group of Companies.
In order to confirm our compliance with the regulations of the EU, the UK. and Switzerland that serve to protect individuals with respect to the “controlling” and “processing” oof personal information as well as to ensure the free movement of personal information within the EU, the UK, and Switzerland through the coordination of national laws, we have implemented a formal privacy policy statement.
To provide you with the full range of services, we may request and/or record information about you. This Privacy Policy explains the following:
Your privacy rights and how to exercise them; the type of information we collect, use, share and protect your personal data; rights of access to your data
EU-US AND SWISS-US PRIVACY FRAMEWORK PRINCIPLES
ComSim and Datawise Services complies with the EU-U.S. Data Privacy program Framework Principles (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy program Framework Principles (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. ComSim and Datawise Services has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Program Principles (EU-U.S. DPF Principles) and the UK Extension with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF. ComSim and Datawise Services has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this policy and the EU-U.S. DPF Principles, the UK Extension to the EU.U.S. DPF Principles, and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit
https://www.dataprivacyframework.gov/.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, ComSim and Datawise Services commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to Datawise Services, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information or to file a complaint. The services of Datawise Services are provided at no cost to you
ComSim Inc.
1200 Summer Street, Suite 101 C
+1 203-336-3360
+1 203-336-3356 (fax)
info@ComSim.com
If your DPF 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 https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2
The Information that ComSim and Datawise Services Receive
ComSim and Datawise Services receive data from our clients with which we have a contractual relationship; data to be used in conducting survey activity on behalf of our clients. These data are defined as “Personal Data” or “Personal Information”: data transferred to the U.S. from the European Union (EU) and Switzerland about or related to an identified or identifiable individual and that can be linked to that individual and that are recorded in any form. This can include information such as your name, postal address, telephone or mobile number, fax number, email address, gender or date of birth. By entering your details in the fields requested, you enable Datawise to provide you with the services you select.
ComSim and Datawise Services as “Data Processor”
ComSim and Datawise Services act as a “Data Processor” and each ComSim and Datawise Services client act as a “Data Controller.” An entity defined as a “Data Processor” carries out an operation or set of operations on Personal Data, such as collecting, recording, storing, disclosing or organizing. A “Data Controller” determines the purposes for which the personal data are processed. As a Data Processor, ComSim and Datawise Services will process personal data only pursuant to the instructions of the client and provide results solely to the client that commissioned the study. ComSim and Datawise Services will not share or use such data for our own marketing purposes.
In the course of our business, ComSim and Datawise Services receive from and/or collects on behalf of our clients’ data that may include, among other things, an individual’s name, address, phone number, email address, title, business account or transaction number, ratings and verbatim comments. All ComSim and Datawise Services employees and contracted agents of ComSim and Datawise Services with access to such personal data are required to read and comply with the ComSim and Datawise Services privacy policy. ComSim and Datawise Services does not receive, collect or process “sensitive personal data,”such as data that indicate a medical or health condition, political opinion, religion, race or ethnic origin, sexual orientation or alleged or actual criminal activity. ComSim and Datawise Services does not receive, collect or process human resource data in the context of the employment relationship.
Adherence to the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework Principles
ComSim and Datawise Services adhere to the Data Privacy Framework Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability.
ComSim and Datawise Services would like to inform individuals that our organization is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Notice
ComSim and Datawise Services will give you timely and appropriate notice describing any personal information we’re collecting, how we’ll use it, and the types of third parties with whom we may share it.
In the introduction or invitation to the survey, prospective respondents are adequately informed as to who is conducting the survey and how the information will be used. Prospective respondents are invited to agree to participate on a voluntary basis.
Choice
In ComSim and Datawise Services’ survey process, all questionnaires for use with respondents in EU and Swiss nations provide the option for their identifying information to be removed. In telephone surveys permission to proceed with the questionnaire is requested by the interviewer and participation is understood by the prospective respondent to be voluntary. When email invitations are sent to prospective respondents ComSim and Datawise Services are fully identified as the requester of information and an “opt out”message is included. If survey respondents elect to be anonymous, their identifying data are removed.
Accountability for Onward Transfer
ComSim and Datawise Services does not disclose to unaffiliated third parties’ data from respondents without permission of the individual to make the disclosure unless disclosure is required by law, the disclosure is reasonably related to the sale of ComSim and Datawise Services’ business, the information is in the public domain, and/or the disclosure is necessary for the establishment of a legal claim. Please be aware that ComSim and Datawise Services may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. ComSim and Datawise Services may transfer personal data to a third party such as translation services, contracted as an agent of ComSim and Datawise Services, provided the contractor has read and agreed in writing to comply with ComSim and Datawise Services’ Privacy Framework Principles and subscribed to the principles. In cases of onward transfer to third parties of data of EU, UK and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Framework Principles, and the UK Extension to the EU-U.S. DPF, ComSim and Datawise Services are liable for appropriate onward transfers of personal data to third parties unless we can prove we were not a party giving rise to the damages.
Access
Pursuant to the DPF Frameworks, ComSim and Datawise Services acknowledge that EU, UK and Swiss individual have the right to access their data that is transferred into the United States. Specifically, individuals have the right to update or amend any personal data that is inaccurate. Furthermore, you have the right to demand deletion of information that has been handled in violation of the DPF Principles. Upon specific request, ComSim and Datawise Services will permit respondents access to any personal data submitted as part of our survey process in order to correct or amend inaccurate information, or delete mishandled data. An individual requesting access may need to provide identifiable information including, but not limited to, name, company, phone number and/or email address. Such access may be limited or denied by ComSim and Datawise Services if providing such access would be disproportionate to the risks to the individual’s privacy, overly burdensome, time consuming, would result in significant and/or unreasonable cost to ComSim and Datawise Services, and/or where the rights of persons other than the individual would be violated.
Security
Reasonable precautions are taken by ComSim and Datawise Services to protect personal data against loss, misuse and unauthorized access, disclosure, alteration and destruction. These precautions include, but are not limited to, password protected data files and websites, data back-up, and secure data servers.
Data Integrity and Purpose Limitation
ComSim and Datawise Services take reasonable steps to ensure that data are reliable for their intended use, as well as accurate, complete and current. Data processed by ComSim and Datawise Services are solely those relevant for the purposes for which they are supplied / collected and to be used.
As stated in the Data Privacy Framework Program Statement, ComSim and Datawise Services confirm to all Privacy Principles required by the EU, the UK and Switzerland. ComSim and Datawise Services’ Research Administrator is responsible for the internal supervision of ComSim and Datawise Services’ privacy policies and their ongoing administration. ComSim and Datawise Services conduct regular self-assessment reviews to ensure full compliance with the Principles. Any reported violations and follow-up actions to address and/or resolve problems or complaints are contained in an assessment document. Self-assessment documents are signed by a ComSim and Datawise Services corporate officer and available upon request by an individual or in the context of an investigation or complaint about non-compliance.
Will Datawise share my information with anyone else?
Datawise may share your data with other companies in the Datawise Group of Companies, including our holding company and its subsidiaries. We may disclose your personal data where Datawise believes it is compelled to do so by law; for the prevention or detection of crime, the capture or prosecution of offenders; and the assessment or collection of tax or duty. We do not require any further consent from you to share your data in such circumstances and Datawise will comply as required with any legally binding request that is made of it. In the event we propose to sell or buy any business assets or any part of our group of companies, we may disclose your personal data to the prospective seller or buyer of such business or assets if relevant, but on a strictly confidential basis. We only disclose or share data within the bounds of the law.
Rights of Access – What personal information Datawise holds on me?
Under GDPR you have the right to access your information and to be aware of and verify the lawfulness of processing and receive confirmation that your data is being processed.
Access to personal data
The purpose of the ‘rights of access’ is for the individual to be aware of and verify the lawfulness for processing. An individual will be asked to specify the information the request relates to and this will be free of charge. Where requests are manifestly unfounded or excessive Datawise will charge a ‘reasonable’ amount taking into account the administrative costs for providing the information.
Information will be provided within one month unless the request is complex. In this case Datawise will contact the individual within one month extending the period up to two months with an explanation as to why the extension is necessary.
If any of the personal information that we hold about you is incorrect, you can contact us at info@comsim.com and we will update your details as soon as practically possible.
Changes to Datawise Privacy Policy
This Privacy Policy may be updated at any time with or without notice to comply with new practices, regulations or the general law. Any changes will be immediately posted on our websites and you will be deemed to have accepted the terms of this Privacy Policy on your first use of any of our sites following the alterations. We recommend that you visit this page to keep up-to-date every time you submit personal information to any of our websites.
How Do We Protect Your Data?
We have put in place security procedures and technical and organizational measures to safeguard your personal information. Access to all internal servers is limited to the IT specialist and Chief Technology Officer.
How Long Do We Keep Your Data?
We do not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed. When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay, however, we are required to keep certain information for audit and tax purposes in which case we hold personal data for up to 10 years.