Our Commitment to Your Privacy
Integrity Interactive Corporation ("Integrity") respects your privacy. This privacy policy (“Policy”) describes Integrity’s privacy practices with respect to the personal information we collect, how the information is used, and under what circumstances the information is disclosed.
We may update this Policy from time to time to reflect new uses, rules, regulations or technologies that impact your privacy. We recommend that you review our Policy on a routine basis to read any updates.
Safe Harbor Policy
Integrity abides by the EU Safe Harbor framework as set forth by the US Department of Commerce regarding the collection, use, and retention of data from the European Union.
Information Collection & Use
Integrity provides a variety of services to client companies and other organizations (“client companies”). Integrity’s primary services include: (i) online ethics and compliance courses, communications, certification and related ethics and compliance risk mitigation services; (ii) online ethics and compliance risk management services with respect to our client companies’ suppliers and other business partners; and (iii) an online system for our client companies to manage ethics and compliance incidents and inquiries and for our client companies’ employees to ask ethics and compliance questions and/or report concerns.
In order to provide these services to our client companies, Integrity may receive from the client company or from a client company employee, supplier, or agent certain personally identifiable information. Any information provided to Integrity in connection with the provision of services to our client companies is treated as the confidential information of the client company, or of the individual or entity supplying the personally identifiable information, as the case may be. Integrity does not divulge this information to third parties, except as described in this Policy, or as authorized by a client company, or as directed by an appropriate law enforcement agency or court of law.
Ethics Courses, Communications, Certification and Similar Services
Integrity contracts with client companies to provide ethics and compliance courses, communications, policy certifications, risk assessments and related services to the client companies’ employees, agents and other individuals (a "user"). In order to provide these services, Integrity must obtain certain personally identifiable information about the user to register him or her for the courses, communications, certifications, risk assessments or other service. For example, this information may include a user’s name, business email address, job title, job location, department and similar information. Client companies often provide this information directly to Integrity, but at times users are asked to provide this information to us via an online form or questionnaire. This information is used to manage the user’s utilization of Integrity’s services, and to provide the client company with information about the user’s utilization of our services.
Supplier Risk Management Services
Integrity also provides an online service whereby client companies can communicate with their suppliers and other business partners regarding ethics and compliance issues. In utilizing this service, our client companies’ suppliers (and other business partners) may be asked to, among other things, certify to a client company policy, complete a client company questionnaire or form, participate in ethics and compliance education or otherwise provide information for use by the client company. In so doing, the supplier or other business partner may provide personally identifiable information, including, for example, a name, address, and telephone number. Integrity uses such personally identifiable information to communicate with the supplier and other business partners, to provide information to our client companies regarding their suppliers’ (or other business partners’) use of Integrity’s services, and to otherwise provide the services requested by our client companies.
Service for Managing Ethics and Compliance Incidents and Inquiries
Integrity also provides an online service (known as the EthicsAdvantage® service) for our client companies’ to manage ethics and compliance incidents and inquiries, and for our client companies’ employees (“reporters”) to report ethics and compliance concerns or to ask ethics and compliance questions. Integrity is not responsible for the content of the information that reporters or client company representatives input or save to this online system.
Integrity’s system does not automatically collect personally identifiable information from reporters. Personally identifying information is stored only when a reporter voluntarily gives this information. Reporters’ communications are sent via an encrypted connection and are accessed by client company personnel as determined by the client company. Reporters have the option of sending their communications anonymously, in which case Integrity does not store or record the reporter’s location, computer or account. Integrity stores reporters’ communications and the related data, responses and reports for use by the reporters’ associated client companies.
Visitors to Integrity’s Web Sites
We collect information from visitors to our websites and from participants in online events such as webinars (collectively, “visitors”) via event registrations, asking questions on our websites and by permitting visitors to communicate directly with Integrity via email. Some of the information that visitors submit may be personally identifiable information. Integrity may use this information for sales and marketing purposes, to invite visitors (and others) to participate in surveys, webinars or other online events, or to send visitors additional information regarding Integrity and its services.
Integrity also may collect, store or accumulate certain other information concerning visitors’ use of our websites and other online services, such as information regarding which web pages are most often visited. Integrity may share with or transfer to third parties such information for the purpose of maintaining the websites, responding to direct inquiries or measuring traffic and traffic trends at our websites.
Cookies and Log Files
A cookie is a piece of data tied to information about a visitor to our web site, or to an individual who uses an Integrity service. While a visitor is on an Integrity site or using an Integrity service, we may use a cookie to store temporary information related to the use of the site or an Integrity service. If you elect not to receive cookies, some pages may not function properly or you might be unable to use some of Integrity’s services. Cookies remain on your computer, and Integrity does not store your cookies on its computers or forward cookies to third parties.
We use IP addresses to analyze trends, administer our website, track movement through our website and gather broad demographic information for aggregate use. IP addresses may be linked to personally identifiable information for security and diagnostic purposes.
Aggregated Data
Integrity collects aggregated data about the usage of our services and websites. We own this data and may share it with others. This aggregated data does not contain any personally identifiable information.
Links
Integrity’s websites may contain links to other sites. Integrity is not responsible for the privacy practices of other sites. We encourage you to read the privacy statements of each website that collects personally identifiable information.
Security
Integrity takes reasonable precautions to protect personally identifiable information in its possession from loss, misuse and unauthorized access or disclosure. Encrypted communications between Integrity’s website and an individual’s web browser are accomplished using industry standard SSL encryption and root authority certificates to protect confidential data. Integrity follows generally accepted industry standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of personally identifiable information supplied to us. If you have questions about security on Integrity’s website or about online services provided by Integrity, please send us an email to privacy@i2c.com.
Unauthorized access of Integrity websites may be a violation of the law. Integrity will take appropriate legal action against anyone who improperly or illegally accesses information on our servers.
Disclosure Pursuant to Subpoenas, Warrants or Orders
We reserve the right to disclose your personally identifiable information as required by law or when we believe that disclosure is necessary to protect our rights or comply with a judicial proceeding, court order, or legal process.
Viewing and Correcting Personal Information
If you would like to view or correct personally identifiable information that we have about you, please send an email to privacy@i2c.com. However, if the information has been provided to us by a client company (rather than directly by you), we can only provide access to such information with the permission of the client company. Please do not send us confidential or private information via email.
Opt-Out
If you believe that your personally identifiable information should not be used as described in this Policy, that you should not be subscribed to an Integrity service to which you have been subscribed, or that you should not be otherwise invited to participate in an Integrity service, please send an explanatory email to privacy@i2c.com. We will discuss your request with the client company which asked us to subscribe you to the Integrity service, or otherwise asked us to invite you (or your company) to participate in one of our services.
If you send us correspondence, such as an email, we may keep and use a copy of that correspondence. We also may share that information with others.
Enforcement of This Policy
If you have questions or concerns about this Policy or Integrity’s privacy practices, please contact us by email at privacy@i2c.com, or by mail at: Privacy Office, Integrity Interactive Corporation, 51 Sawyer Rd., Suite 510, Waltham, MA 02453, USA.
Changes to This Policy
Integrity may modify this Policy at any time. If we decide to change this Policy, we will post the changes to this Policy on Integrity’s website(s) and other places we deem appropriate.
Revised April 2009