PRIVACY SHIELD

https://www.privacyshield.gov/participant?id=a2zt00000008VB9AAM&status=Active

ACE RELOCATION SYSTEMS, INC. is committed to the Privacy Shields’ Principles covering all Personal Data received by ACE RELOCATION SYSTEMS, INC. in the U.S. from European Union member countries and Switzerland in reliance on the respective Privacy Shield framework.

  1. Notice

ACE RELOCATION SYSTEMS, INC. is participating in Privacy Shield and can be found on the Privacy Shield list at https://www.privacyshield.gov/list. ACE RELOCATION SYSTEMS, INC. collects personal data related to people from European Union countries and Switzerland to facilitate movement of said person’s goods. ACE RELOCATION SYSTEMS, INC. can be contacted at 858-677-5500 or Privacyshield@acerelocation.com. ACE RELOCATION SYSTEMS, INC. notifies Data Subjects covered by this Choice Privacy Shield Policy about its data practices regarding Personal Data received by ACE RELOCATION SYSTEMS, INC. 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 ACE RELOCATION SYSTEMS, INC. offers for limiting its use and disclosure of such Personal Data, how ACE RELOCATION SYSTEMS, INC.’s obligations under the Privacy Shield are enforced, and how Data Subjects can contact ACE RELOCATION SYSTEMS, INC. with any inquiries or complaints.

  1. 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, ACE RELOCATION SYSTEMS, INC. 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@acerelocation.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, ACE RELOCATION SYSTEMS, INC. will obtain the Data Subject’s explicit consent prior to such use or disclosure.

  1. 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 ACE RELOCATION SYSTEMS, INC. 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, ACE RELOCATION SYSTEMS, INC. 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 ACE RELOCATION SYSTEMS, INC. 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 ACE RELOCATION SYSTEMS, INC.’s obligations under the Privacy Shield Principles; and (iv) require the agent to notify ACE RELOCATION SYSTEMS, INC. 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.

ACE RELOCATION SYSTEMS, INC. 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 ACE RELOCATION SYSTEMS, INC. is not responsible for the event giving rise to the damage.

ACE RELOCATION SYSTEMS, INC is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements

  1. Security

ACE RELOCATION SYSTEMS, INC. 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.

  1. Data Integrity and Purpose Limitation

ACE RELOCATION SYSTEMS, INC. limits the collection of Personal Data covered by this Privacy Shield Policy to information that is relevant for the purposes of processing. ACE RELOCATION SYSTEMS, INC. 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.

ACE RELOCATION SYSTEMS, INC. takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. ACE RELOCATION SYSTEMS, INC. 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 ACE RELOCATION SYSTEMS, INC.’s obligations to comply with professional standards, ACE RELOCATION SYSTEMS, INC.’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.

  1. 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@acerelocation.com

 

  1. Recourse, Enforcement, and Liability

ACE RELOCATION SYSTEMS, INC.’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, ACE RELOCATION SYSTEMS, INC. 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 ACE RELOCATION SYSTEMS, INC. at: privacyshield@acerelocation.com

ACE RELOCATION SYSTEMS, INC. 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, JAMS at https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim.

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.

ACE RELOCATION SYSTEMS, INC. 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. ACE RELOCATION SYSTEMS, INC. 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.