DiscoverOrg Privacy Policy for Personal Information under the U.S. – EU Safe Harbor Framework and the U.S. – Swiss Safe Harbor Framework

I. Policy

DiscoverOrg, LLC and its affiliated U.S. entities (“DiscoverOrg,” “the company”) comply with the U.S. – EU Safe Harbor Framework and the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. DiscoverOrg has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view DiscoverOrg’s certification, please visit http://www.export.gov/safeharbor/.

This Safe Harbor Privacy Policy outlines DiscoverOrg’s general policy and practices for implementing these Principles, including the types of Personal Information DiscoverOrg gathers, how it is used, the choices affected individuals have regarding such use, and their ability to correct the Personal Information relating to them.

II. Definitions

For the purpose of this Safe Harbor Privacy Policy, the following definitions apply:

“Personal Information” means information:

  • Transferred from the EU or Switzerland to the United States, and
  • Pertaining to a specific individual or linked to such individual that identifies or can be used to identify such individual.
  • “Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sexual orientation.

III. Scope

This policy governs all Personal Information collected and processed by DiscoverOrg (the “Information”). DiscoverOrg collects and processes the following Information regarding certain individuals: Job title and job function, business telephone number, and business email address. The Information, along with other non-personal information, is maintained in a proprietary database to which DiscoverOrg provides subscription access. DiscoverOrg collects Personal Information from individuals only in accordance with the Principles and does not collect any Sensitive Personal Information.

IV. Notice and Choice

DiscoverOrg notifies each individual to which any Information pertains about the Information collected, how it is used, and how to contact the company when concerns over privacy occur. DiscoverOrg provides notice through this Safe Harbor Privacy Policy and through direct communication with the individuals from whom we collect Personal Information.

Every individual to whom any Information pertains is given the opportunity to opt out of collection, processing, disclosure, and/or onward transfer of such Information. Information will only be used in a manner that is consistent with the purpose provided in the relevant notice.

V. Disclosure and Onward Transfers

Disclosure and onward transfer of Information is subject to the Notice and Choice policies stated above. If any individual to whom any Information pertains opts out of disclosure and onward transfer of such Information, DiscoverOrg will not disclose or transfer such information to any third party unless such third party is an agent of DiscoverOrg and subscribes to the Principles.

Unless an individual opts out of disclosure and onward transfer, or out of collection and processing, the Information shall remain part of DiscoverOrg’s proprietary sales and marketing information database. Any or all of this information may be transferred by electronic transmission to third parties to whom DiscoverOrg provides subscription access.

DiscoverOrg may also disclose or transmit any information contained in its database if:

  • DiscoverOrg has obtained the individual’s permission to make the disclosure.
  • The disclosure is required by law, legal process, or mandatory professional standards.
  • The disclosure is reasonably related to the sale or other disposition of all or part of the company’s business.
  • The information disclosed is publicly available.

VI. Access

Each individual to whom any Information pertains may request, and upon request will be provided, access to such Information and will be allowed to correct, amend, or delete such Information where it is inaccurate, unless doing so would violate the rights of other persons. DiscoverOrg may limit or deny access to the Information in circumstances in which providing access would be unreasonably burdensome or expensive, or as otherwise permitted by the Principles. Where warranted, DiscoverOrg may charge a reasonable fee for access to Personal Information.

VII. Data Security and Integrity

DiscoverOrg employs various physical, electronic, educational, and training measures to provide reasonable protection from loss, misuse, or unauthorized access, disclosure, alteration, or destruction of the Information. These measures include password protection, encryption, and training of employees and clients regarding appropriate access to and use of the Information, as well as restrictions on transfer.

DiscoverOrg ensures that the Information is relevant to the purpose for which it was collected and processed, and takes reasonable steps to ensure that the Information is reliable for its intended use, accurate, complete, and current.

VIII. Enforcement and Dispute Resolution

DiscoverOrg will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that DiscoverOrg determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

Any questions or concerns regarding the use or disclosure of the Information should be directed to the DiscoverOrg Privacy Office at privacy@discoverorg.com. DiscoverOrg will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Information by reference to the principles contained in this Policy. For complaints that cannot be resolved between DiscoverOrg and the complainant, DiscoverOrg agrees to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

  • For all disputes involving Information received by DiscoverOrg from Switzerland, DiscoverOrg has agreed to cooperate with the Swiss FDPIC;
  • For all other disputes, DiscoverOrg has agreed to binding arbitration by JAMS pursuant to the JAMS Streamlined Arbitration Rules. Individuals who submit a question or concern to DiscoverOrg and feel it has not been satisfactorily addressed may contact the JAMS directly via its website http://www.jamsadr.com/.

The dispute resolution process shall be conducted in English.

IX. Changes to This Safe Harbor Privacy Policy

DiscoverOrg periodically reviews this Policy to ensure that it is consistent with the requirements of the Principles. Changes to this Policy will be posted on DiscoverOrg’s corporate website.