Privacy Shield Policy (Last updated August 3, 2017)

ANONOS INC., a U.S. company organized under the laws of the state of Delaware (“ANONOS,” “we,” “our,” and “us”), complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data (as defined below) from European Union member countries and Switzerland. ANONOS has certified that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability. If there is any conflict between the policies in this ANONOS Privacy Shield Policy (“Privacy Shield 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 page, please visit https://www.privacyshield.gov/.

Definitions

“Data Subject” means the individual to whom any given Personal Data covered by this Privacy Shield Policy refers.

“Personal Data” means any information relating to an individual residing in the European Union and Switzerland that can be used to identify that individual either on its own or in combination with other readily available data.

“Sensitive Personal Data” means Personal Data regarding an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual life.

Scope and Responsibility

This Privacy Shield Policy applies to Personal Data transferred from European Union member countries and Switzerland to ANONOS’s operations in the U.S. in reliance on the respective Privacy Shield framework and does not apply to Personal Data transferred under Standard Contractual Clauses or any approved derogation from the EU Directive. Some types of Personal Data may be subject to other privacy-related requirements and policies.

All employees of ANONOS that have access in the U.S. to Personal Data covered by this Privacy Shield Policy are responsible for conducting themselves in accordance with this Privacy Shield Policy. Adherence by ANONOS to this Privacy Shield Policy may be limited to the extent required to meet legal, regulatory, governmental, or national security obligations, but Personal Data covered by this Privacy Shield Policy shall not be collected, used, or disclosed in a manner contrary to this policy without the prior written permission of ANONOS’ Chief Privacy Officer.

ANONOS employees responsible for engaging third parties to which Personal Data covered by this Privacy Shield Policy will be transferred are responsible for obtaining appropriate assurances that such third parties have an obligation to conduct themselves in accordance with the applicable provisions of this Privacy Shield Principles, including any applicable contractual assurances required by Privacy Shield.

Privacy Shield Principles

ANONOS commits to subject to the Privacy Shields’ Principles all Personal Data received by ANONOS in the U.S. from European Union member countries and Switzerland in reliance on the respective Privacy Shield framework.

1. Notice

ANONOS notifies Data Subjects covered by this Choice Privacy Shield Policy about its data practices regarding Personal Data received by ANONOS in the U.S. from European Union member countries and Switzerland in reliance on the respective Privacy Shield framework, including the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data, the types of third parties to which it discloses such Personal Data and the purposes for which it does so, the rights of Data Subjects to access their Personal Data, the choices and means that ANONOS offers for limiting its use and disclosure of such Personal Data, how ANONOS’s obligations under the Privacy Shield are enforced, and how Data Subjects can contact ANONOS with any inquiries or complaints.

2. Choice

If Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, ANONOS will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to: privacyshield@anonos.com.

If Sensitive Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a third party, ANONOS will obtain the Data Subject’s explicit consent prior to such use or disclosure.

3. Accountability for Onward Transfer

In the event we transfer Personal Data covered by this Privacy Shield Policy to a third party acting as a controller, we will do so consistent with any notice provided to Data Subjects and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If ANONOS has knowledge that a third party acting as a controller is processing Personal Data covered by this Privacy Shield Policy in a way that is contrary to the Privacy Shield Principles, ANONOS will take reasonable steps to prevent or stop such processing.

With respect to our agents, we will transfer only the Personal Data covered by this Privacy Shield Policy needed for an agent to deliver to ANONOS the requested product or service. Furthermore, we will (i) permit the agent to process such Personal Data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the Privacy Shield Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data transferred in a manner consistent with ANONOS’s obligations under the Privacy Shield Principles; and (iv) require the agent to notify ANONOS if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.

ANONOS remains liable under the Privacy Shield Principles if an agent processes Personal Data covered by this Privacy Shield Policy in a manner inconsistent with the Principles, except where ANONOS is not responsible for the event giving rise to the damage.

4. Security

ANONOS takes reasonable and appropriate measures to protect Personal Data covered by this Privacy Shield Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.

5. Data Integrity and Purpose Limitation

ANONOS limits the collection of Personal Data covered by this Privacy Shield Policy to information that is relevant for the purposes of processing. ANONOS does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject.

ANONOS takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. ANONOS takes reasonable and appropriate measures to comply with the requirement under the Privacy Shield to retain Personal Data in identifiable form only for as long as it serves a purpose of processing, which includes ANONOS’s obligations to comply with professional standards, ANONOS’s business purposes and unless a longer retention period is permitted by law, and it adheres to the Privacy Shield Principles for as long as it retains such Personal Data.

6. Access

Data Subjects whose Personal Data is covered by this Privacy Shield Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the Privacy Shield Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment, or deletion should be sent to: privacyshield@anonos.com.

7. Recourse, Enforcement, and Liability

ANONOS’s participation in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework is subject to investigation and enforcement by the Federal Trade Commission.

In compliance with the Privacy Shield Principles, ANONOS commits to resolve complaints about your privacy and our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding this Privacy Shield Policy should first contact ANONOS at: privacyshield@anonos.com.

ANONOS has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the International Centre for Dispute Resolution® (“ICDR®”) - the international division of the American Arbitration Association® (“AAA®”). If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.icdr.org/icdr/faces/i_search/i_rule/i_rule_detail?doc=ADRSTAGE2025301&_afrLoop=905259316358957&_afrWindowMode=0&_afrWindowId=null#%40%3F_afrWindowId%3Dnull%26_afrLoop%3D905259316358957%26doc%3DADRSTAGE2025301%26_afrWindowMode%3D0%26_adf.ctrl-state%3Dtwovzxky1_40 for more information and to file a complaint.

Under certain conditions detailed in the Privacy Shield, Data Subjects may be able to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

ANONOS agrees to periodically review and verify its compliance with the Privacy Shield Principles, and to remedy any issues arising out of failure to comply with the Privacy Shield Principles. ANONOS acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Privacy Shield participants.

Changes to this Privacy Shield Policy

This Privacy Shield Policy may be amended from time to time consistent with the requirements of the Privacy Shield. Appropriate notice regarding such amendments will be given.

Privacy Policy

This website is operated by Anonos Inc. or affiliates of Anonos Inc. This policy describes how this website collects and shares data including personal information. In the context of this policy, "personal information" means information that identifies you such as your name, address, email address or similar contact information. By continuing to use this website, you explicitly consent to the terms of this policy. We may monitor and analyze the performance of this site.

We may collect data in server logs, like web requests, data sent in response to requests, browser type, browser language, Internet Protocol address and timestamp for requests. This information may be used to maintain functionality of this site. We do not collect personal information automatically for monitoring or performance analysis purposes. We take reasonable steps to secure data.

We have systems, policies, and procedures in place to provide reasonable protection against unauthorized access, use, or alteration of our collected data including personal information.

We do not share personal information without your consent, unless:
  • Doing so is legally required; or
  • To otherwise protect our property, legal rights, or those of others.
If Anonos ever files for bankruptcy or has it's assets sold to or merged with another entity, information we receive from you from this website is an asset that may be transferred.

Google Analytics
This site uses Google Analytics Demographics and Interest Reporting to track user activity. This enables Google Analytics to collect data about traffic on this site via Google advertising cookies and identifiers, in addition to data collected through a standard Google Analytics implementation. Anonos will not identify users or facilitate the merging of personally identifiable information with non-personally identifiable information collected through any Google advertising product or feature without first securing users’ prior affirmative (i.e., opt-in) consent to, that identification or merger. Irrespective of user consent, Anonos will not attempt to disaggregate data that Google reports in aggregate. If you wish to opt-out of Google Analytics, download and install the Google opt-out add-on for your web browser. The Google Analytics opt-out add-on is designed to be compatible with Chrome, Internet Explorer 11, Safari, Firefox and Opera. In order to function, the opt-out add-on must be able to load and execute properly on your browser. For Internet Explorer, 3rd-party cookies must be enabled. Learn more about the opt-out and how to properly install the browser add-on here.

Pardot
This web site uses Pardot, a data analysis tool. Pardot sets cookies for tracking purposes, and sets third-party cookies for redundancy. Using first-party and third-party cookies together is standard in the data analytics industry. Pardot cookies do not store personally identifying information, they store only a unique identifier. Pardot tracks visitor and prospect activities on this website and on Pardot landing pages by setting cookies. These cookies are set in order to remember preferences (like form field values) when a visitor returns to this site.

Questions
If you have any questions, comments, or suggestions regarding this policy, please contact us at privacypolicy@anonos.com.