BI WORLDWIDE has adopted this Privacy Shield Policy
("Policy") to declare its commitment to comply with Privacy Shield
Principles by establishing and maintaining an adequate level of Personal Data
privacy protection. This Policy applies to the processing of Personal Data that
BIWORLDWIDE obtains from customers and Individuals in the European Union, the United Kingdom, and
BI WORLDWIDE complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US
Department of Commerce regarding the collection, use, and retention of personal
information transferred from European Union and Switzerland to the United
BI WORLDWIDE has
certified to the Department of Commerce that it adheres to the
Privacy Shield Principles of notice,
choice, accountability for onward transfer, security, data integrity and
purpose limitation, access, recourse, enforcement and liability
. If there is any conflict between the
terms in this 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/ The Federal Trade Commission (FTC) has
compliance with the Privacy Shield. All BI WORLDWIDE employees who handle
Personal Data from Europe and Switzerland are required to comply with the
Principles stated in this Policy.
provides services to businesses.
applies to the processing of Individual Personal Data that BI WORLDWIDE
receives in the United States relating to Individuals who reside in the
European Union and Switzerland.
does not cover data from which individual persons cannot be identified or
situations in which pseudonyms are used. (The use of pseudonyms involves the
replacement of names or other identifiers with substitutes so that
identification of individual persons is not possible.)
II. RESPONSIBILITIES AND MANAGEMENT
BI WORLDWIDE has designated its Legal
Department, Data Privacy Managers, and Information Security Officers (“Security
and Privacy Team”) to oversee its information security program, including its
compliance with the EU and Swiss Privacy Shield program. BI WORLDWIDE’s Security
and Privacy Team shall review and approve any material changes to this information
security program as necessary. Any questions, concerns, or comments regarding
this Policy also may be directed to
DPO.US@biworldwide.com. BI WORLDWIDE will maintain, monitor, test,
and upgrade information security policies, practices, and systems to assist in
protecting the Personal Data that it collects. BI WORLDWIDE personnel will
receive training, as applicable, to effectively implement this Policy.
III. RENEWAL / VERIFICATION
BI WORLDWIDE will renew its US-EU Privacy
Shield and Swiss-US Privacy Shield certifications annually unless it
subsequently determines that it no longer needs such certification, or if it
employs a different adequacy mechanism.
Prior to the re-certification, BI WORLDWIDE
will conduct an in-house verification to ensure that its attestations and
assertions about its treatment of Individual Personal Data are accurate and
that the company has appropriately implemented these practices. Specifically,
as part of the verification process, BI WORLDWIDE will undertake the following:
Review this Privacy Shield policy and its publicly posted website
regarding the collection and use of Personal Data.
Individuals of BI WORLDWIDE's participation in the US EU Privacy Shield and US
Swiss Privacy Shield programs and where to obtain a copy of additional
information (e.g., a copy of this Policy).
Ensure that this Policy continues to comply with the Privacy Shield
Confirm that customers and Individuals are made aware of the process for
addressing complaints and any independent dispute resolution process (BI
WORLDWIDE may do so through its publicly posted website, each separate customer
contract, or both).
Review its processes and procedures for training BI WORLDWIDE employees
about BI WORLDWIDE's participation in the Privacy Shield programs and the appropriate
handling of Individual Personal Data.
IV. COLLECTION AND USE OF PERSONAL DATA
BI WORLDWIDE collects Personal Data directly from
Individuals when they register with one of our websites, login to their
account, participate in reward and recognition programs, participate in meetings,
events, and travel programs, redeem award points for individual travel or merchandise,
request information, or otherwise communicate with us.
BI WORLDWIDE also receives Individual Personal
Data indirectly from its business customers (Data Controllers) in its role as a
service provider (Data Processor).
The Personal Data that we collect may vary
based on the Individual’s interaction with one or more of our websites used to
provide the services as agreed under contract with our business customers. In
general, BI WORLDWIDE collects the following types of Personal Data either
directly from Individuals, or indirectly from BI WORLDWIDE business customers:
contact information, including, a contact person's name, work email address,
work mailing address, delivery address for merchandise award delivery, work
telephone number, title, and company name. Individuals have the option to log
into their accounts online and request assistance via an online form or through
a live support option such as chat or telephone, collectively “Portals”.
In such cases, we will collect information
that they choose to provide to us through these Portals.
When Individuals use our services online, we
will collect their IP address and browser type. The information that we collect
from Individuals is used for providing services, managing transactions,
reporting, other operations related to providing services and products to the
Individual and/or to BI WORLDWIDE customers in accordance with their contracts.
BI WORLDWIDE acts as a service provider to
In our capacity as a service
provider, we will receive, store, and/or process Personal Data. In such cases,
we are acting as a Data Processor and will process the Personal Data on behalf
of, and under the direction of our customers (Data Controllers). The Personal
Data that we collect from Individuals in this capacity is used to provide
services to the Individual as requested by the Data Controller.
BI WORLDWIDE uses Personal Data that it
collects directly from Individuals, or indirectly from our customers in our
role as a service provider for the following business purposes, without
delivering and providing the requested products/services, and complying
with its contractual obligations related thereto (including managing
transactions, reporting, and other operations related to providing services to
our customers and Individuals);
satisfying governmental reporting, tax, and other requirements (e.g.,
storing and processing data, including Personal Data, in computer
databases and servers located in the United States;
verifying identity (e.g., for online access to accounts);
as requested by the Individual;
for other business-related purposes permitted or required under
applicable local law and regulation, and
as otherwise required by law.
BI WORLDWIDE does not disclose Personal Data
to third parties for purposes that are materially different than as specified
as the original purpose. Should this change in the future, we will provide affected
individuals with the option to opt-out.
V. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
BI WORLDWIDE discloses relevant Personal Data only to a Third
Party who reasonably needs to know such Personal Data, and only under a
contract with the Third Party that provides that such data may only be processed
for limited and specified purposes consistent with the consent provided by the
Individual and for no other purpose. Third Party recipients must agree to
provide the same level of protection as the Privacy Shield Principles and will
notify BI WORLDWIDE if it determines that it can no longer meet this
The Third Party contract
must provide that when such a determination is made, the Third Party controller
must cease processing or take other reasonable and appropriate steps to
BI WORLDWIDE may provide Personal Data to Third Parties
that act as agents, consultants, and contractors to perform tasks on behalf of
and under our instructions. For example, BI WORLDWIDE may store such Personal
Data in facilities operated by Third Parties. Such Third Parties must agree to
use such Personal Data only for the purposes for which they have been engaged
by BI WORLDWIDE and they must either:
1.comply with the Privacy Shield principles or another mechanism permitted
by the applicable EU & Swiss data protection law(s) for transfers and
processing of Personal Data;
2.or agree to provide adequate protections for the Personal Data that are
no less protective than those set out in this Policy;
BI WORLDWIDE also may disclose Personal Data for other
purposes or to other Third Parties when a Data Subject has consented to or
requested such disclosure. Please be aware that BI WORLDWIDE may be required to
disclose an individual's personal information in response to a lawful request
by public authorities such as for national security or law enforcement
requirements. BI WORLDWIDE is liable for appropriate onward transfers of
personal data to third parties.
VI. SENSITIVE DATA
In general, BI WORLDWIDE does not receive or collect
Sensitive Data from Individuals. Within specific services provided by BI
WORLDWIDE, and as contractually required and directed by a BI WORLDWIDE customer,
some sensitive data may be required.
such cases, Individuals will be provided with information to explain why that
data is required.
VII. DATA INTEGRITY AND SECURITY
BI WORLDWIDE uses reasonable efforts to
maintain the accuracy and integrity of Personal Data and to update it as
appropriate. BI WORLDWIDE has implemented physical and technical safeguards to
protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration,
or destruction. BI WORLDWIDE also employs access restrictions, limiting the
scope of employees who have access to Personal Data. Further, BI WORLDWIDE uses
secure encryption technology to protect certain categories of personal data.
Despite these precautions, no data security safeguards guarantee 100% security
all of the time.
BI WORLDWIDE notifies Individuals about its
adherence to the EU-US Privacy Shield and Swiss-US Privacy Shield principles
through this policy which is accessible from the Privacy Shield certification
https://www.privacyshield.gov/ and from each website hosted by BI WORLDWIDE.
IX. ACCESSING PERSONAL DATA
BI WORLDWIDE personnel may access and use
Personal Data only if they are authorized to do so, only for the purpose for
which they are authorized and limited only to Personal Data relevant to the
purpose of processing.
X. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
Right to Access. Individuals have the right to know what Personal Data about them is
included in the databases and to ensure that such Personal Data is accurate and
relevant for the purposes for which BI WORLDWIDE collected it. Individuals may
review their own Personal Data stored in the databases and request to have it corrected,
erased, or blocked, as permitted by applicable law and BI WORLDWIDE policies.
Upon reasonable request and as required by the Privacy Shield principles, BI
WORLDWIDE allows Individuals access to their Personal Data, in order to correct
or amend such data where inaccurate. Individuals may edit their Personal Data
by logging into their account profile or by contacting BI WORLDWIDE by email or
other means provided by the website. In making modifications to their Personal
Data, Data Subjects must provide only truthful, complete, and accurate
information. To request erasure of Personal Data, Individuals should submit a
written request via email to
Requests for Personal
. BI WORLDWIDE will track each of the
following and will provide notice to the appropriate parties under law and
contract when either of the following circumstances arise: (a) legally binding
request for disclosure of the Personal Data by a law enforcement authority
unless prohibited by law or regulation; or (b) requests received from the Data
Satisfying Requests for
Access, Modifications, and Corrections
WORLDWIDE will endeavor to respond in a timely manner to all reasonable written
requests to view, modify, or inactivate Personal Data.
XI. CHANGES TO THIS POLICY
This Policy may be amended from time to time,
consistent with the Privacy Shield Principles and applicable data protection
and privacy laws and principles. We will make employees aware of changes to
this policy either by posting to our intranet, through email, or other means.
We will notify affected Individuals if we make changes that materially affect
the way we handle Personal Data previously collected, and we will allow them to
choose whether their Personal Data may be used in any materially different
XII. QUESTIONS OR COMPLAINTS
EU and Swiss Individuals may contact BI
WORLDWIDE with questions or complaints concerning this Policy at the following email
XIII. ENFORCEMENT AND DISPUTE RESOLUTION
In compliance with the US-EU and Swiss-US
Privacy Shield Principles, BI WORLDWIDE commits to investigate and resolve
complaints about your privacy and our collection or use of your personal
information at no cost to the Individual. EU and Swiss individuals with
questions or concerns about the use of their Personal Data should contact us
DPO.US@biworldwide.com.Individuals may bring a
complaint directly to BI WORLDWIDE, and BI WORLDWIDE will respond to the
complaint within 45 days.
If an Individual’s question or concern cannot
be satisfied through this process BI WORLDWIDE has further committed to refer
unresolved privacy complaints under US-EU Privacy Shield and Swiss-US Privacy
Shield to the EU Data Protection Authorities (DPAs).
If you do not receive timely acknowledgement
of your complaint, or if your complaint is not satisfactorily addressed by BI
WORLDWIDE, EU and Swiss individuals may bring a complaint before the EU Data
Protection Authorities (DPAs) or the Swiss Federal Data Protection and
Finally, as a last resort, BI WORLDWIDE will
commit to binding arbitration through the Privacy Shield Panel at the request
of an EU or Swiss Individual.
XIV. DEFINED TERMS
the following meanings:
means an Individual from EU or Switzerland. The term also shall include any
employee of a BI WORLDWIDE customer where BI WORLDWIDE has obtained his or her
Personal Data from such Individual as part of the customer’s business
relationship with BI WORLDWIDE.
" means an identified or identifiable natural living person. An
identifiable person is one who can be identified, directly or indirectly, by
reference to a name, or to one or more factors unique to his or her personal
physical, psychological, mental, economic, cultural or social characteristics.
For Individuals residing in Switzerland, a Data Subject also may include a
means an employee (whether temporary, permanent, part-time, or contract),
former employee, independent contractor, or job applicant of BI WORLDWIDE or
any of its affiliates or subsidiaries, who is also a resident of a country
within the European Economic Area.
European" refers to a
country in the European Union.
" means data that personally identifies or may be used to
personally identify a person, including an individual's name in combination
with country of birth, marital status, emergency contact, salary information,
terms of employment, job qualifications (such as educational degrees earned),
address, phone number, e-mail address, user ID, password, and identification
numbers. Personal Data does not include data that is de-identified, anonymous,
or publicly available. For Switzerland, the term "person" includes
both a natural person and a legal entity, regardless of the form of the legal
" means Personal Data that discloses a Data Subject's medical or
health condition, race or ethnicity, political, religious or philosophical
affiliations or opinions, sexual orientation, or trade union membership.
" means any individual or entity that is neither BI WORLDWIDE nor
a BI WORLDWIDE employee, agent, contractor, or representative.