Privacy Shield

CATS Software, Inc (“CATS”) has adopted this Privacy Shield Policy ("Policy") to establish and maintain an adequate level of personal data privacy protection. This Policy applies to the processing of personal data that CATS obtains from customers.

CATS complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. CATS has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

Scope

This Policy applies to all personal information received by CATS in the United States concerning EU customers.

In most cases, the data we receive will relate to our clients and their business activities and may include personal information about our clients’ employees, business contacts, customers and any other individuals with whom our clients have dealings. When we collect and process personal information provided to us by our clients we do so as a data processor, acting on the instructions of our clients.

Renewal

CATS will renew this Privacy Shield Policy annually using the self-certification method, unless it determines that the Policy no longer needs such certification.

Onward Transfers

CATS will reasonably attempt to ensure its agents will safeguard personal information consistently with this Policy. An “agent” is any third party that collects or uses personal information in order to perform tasks on behalf of CATS. Where CATS has knowledge that an agent is using or disclosing personal information in a manner contrary to this policy, CATS will take reasonable steps to prevent or stop the use or disclosure. Under the Privacy Shield, CATS may be liable for onward transfer of personal data to third parties.

Access

Upon request, CATS will grant individuals reasonable access to personal information that it holds about them through our clients. In addition, CATS will take reasonable steps to permit individuals to correct, amend, or delete information that is shown to be inaccurate or incomplete.

CATS is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Security

CATS will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Dispute Resolution

In compliance with the Privacy Shield Principles, CATS commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CATS by emailing privacy@catsone.com.

As part of this agreement, CATS subjects itself to the investigatory and enforcement powers of the Federal Trade Commission (FTC). In addition, CATS commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the UI in the context of the employment relationship.

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Changes to Privacy Shield Policy

This policy may be amended from time to time, consistent with the requirements of the Privacy Shield principles. Changes to this Policy shall be posted on our website. We encourage you to review this Privacy Shield Policy from time to time for any changes. The effective date of this policy is December 5, 2017.