IntelliBoard Inc. ("IntelliBoard") has adopted this Privacy Shield Policy ("Policy") to establish
and maintain an adequate level of Personal Data privacy protection. This Policy applies to the
processing of Personal Data that IntelliBoard obtains from Customers located in the European
Union and Switzerland.
IntelliBoard complies with the US-EU Privacy Shield Framework and Swiss-US Privacy Shield
Framework as set forth by the US Department of Commerce regarding the collection, use, and
retention of personal information from Individual Customers in the European Union member
countries and Switzerland. IntelliBoard has certified that it adheres to the Privacy Shield
Privacy Principles of notice, choice, accountability for onward transfer, security, data
integrity and purpose limitation, access, recourse, enforcement and liability. If there is any
the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield
program, and to view our certification page, please visit
The Federal Trade Commission (FTC) has jurisdiction over IntelliBoard's compliance with the
All IntelliBoard employees who handle Personal Data from Europe and Switzerland are required to
comply with the Principles stated in this Policy.
Capitalized terms are defined in Section 14 of this Policy.
This Policy applies to the processing of Individual Customer Personal Data that
IntelliBoard receives in the United States concerning Individual Customers who reside in
the European Union and Switzerland. IntelliBoard provides products and services to
businesses and consumers.
This Policy 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.)
2. Responsibilities and management
IntelliBoard has designated the Legal Department to oversee its information security
program, including its compliance with the EU and Swiss Privacy Shield program. The
Legal Department shall review and approve any material changes to this program as
necessary. Any questions, concerns, or comments regarding this Policy also may be
IntelliBoard will maintain, monitor, test, and upgrade information security policies,
practices, and systems to assist in protecting the Personal Data that it collects.
IntelliBoard personnel will receive training, as applicable, to effectively implement
this Policy. Please refer to Section 7 for a discussion of the steps that IntelliBoard
has undertaken to protect Personal Data.
3. Renewal / Verification
IntelliBoard 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, IntelliBoard will conduct an
in-house verification to ensure that its attestations and assertions about its treatment
of Individual Customer Personal Data are accurate and that the company has appropriately
implemented these practices. Specifically, as part of the verification process,
IntelliBoard will undertake the following:
ensure that these policies accurately describe the practices regarding the
collection of Individual Customer Personal Data.
IntelliBoard'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
- Ensure that this Policy continues to comply with the Privacy Shield principles.
- Confirm that Individual Customers are made aware of the process for addressing
complaints and any independent dispute resolution process (IntelliBoard may do so
through its publicly posted website, Individual Customer contract, or both).
- Review its processes and procedures for training Employees about IntelliBoard's
participation in the Privacy Shield programs and the appropriate handling of
Individual's Personal Data.
IntelliBoard will prepare an internal verification statement on an annual basis.
4. Collection And Use Of Personal Data
IntelliBoard provides various solutions to its Individual Customers who purchase its
products. IntelliBoard collects Personal Data from Individual Customers when they
purchase its products, register with our website, log-in to their account, complete
surveys, request information or otherwise communicate with us. For example, IntelliBoard
individual customers may choose to seek live support or post to a message board.
The Personal Data that we collect may vary based on the Individual Customer's interaction
with our website and request for our services. As a general matter, IntelliBoard
collects the following types of Personal Data from its Individual Customers: contact
information, including, a contact person's name, work email address, work mailing
address, work telephone number, title, and company name, as well as payment information
(which might include credit card and/or bank account information). Individual customers
have the option to log into their accounts online and to request service online,
including through a live support option; we will collect information that they choose to
provide to us through these portals.
When Individual Customers use our services online, we will collect their IP address and
browser type. We may associate IP address and browser type with a specific customer. We
also may collect Personal Data from persons who contact us through our website to
request additional information; in such a situation, we would collect contact
information (as discussed above) and any other information that the person chooses to
submit through our website.
The information that we collect from Individual Customers is used for selling the
products and services they buy from us, managing transactions, reporting, invoicing,
renewals, other operations related to providing services and products to the Individual
For certain products, IntelliBoard serves as a service provider. 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 information on behalf of
and under the direction of our partners and/or agents. The information that we collect
from our Individual Customers in this capacity is used for managing transactions,
reporting, invoicing, renewals, other operations related to providing services to the
Individual Customer, and as otherwise requested by our partner and/or re-seller
IntelliBoard uses Personal Data that it collects directly from its
Individual Customers and for its partners indirectly in its role as a service provider
for the following business purposes, without limitation:
- maintaining and supporting its products, delivering and providing the requested
products/services, and complying with its contractual obligations related thereto
(including managing transactions, reporting, invoices, renewals, and other
operations related to providing services to a Individual Customer);
- satisfying governmental reporting, tax, and other requirements (e.g.,
- storing and processing data, including Personal Data of individuals residing in
European Union, in computer databases and servers located in the European Union;
- verifying identity (e.g., for online access to accounts);
- as requested by the Individual Customer;
- for other business-related purposes permitted or required under applicable local law
- and as otherwise required by law.
IntelliBoard does not disclose personal information to third parties for purposes that
are materially different than what it was originally collected for. Should this change
in the future, we will provide individuals with the option to opt-out.
5. Disclosures / Onward Transfers Of Personal Data
Except as otherwise provided herein, IntelliBoard discloses Personal Data only to Third
Parties who reasonably need to know such data only for the scope of the initial
transaction and not for other purposes. Such recipients must agree to abide by
IntelliBoard 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, IntelliBoard may store such Personal Data in the 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 IntelliBoard and they must
- comply with the Privacy Shield principles or another mechanism permitted by the
applicable EU & Swiss data protection law(s) for transfers and processing of
- or agree to provide adequate protections for the Personal Data that are no less
protective than those set out in this Policy;
IntelliBoard 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
IntelliBoard may be required to disclose an individual's personal information in
response to a lawful request by public authorities, including to meet national security
or law enforcement requirements. IntelliBoard is liable for appropriate onward transfers
of personal data to third parties.
6. Sensitive Data
IntelliBoard does not collect Sensitive Data from its Individual Customers.
7. Data Integrity And Security
IntelliBoard uses reasonable efforts to maintain the accuracy and integrity of Personal
Data and to update it as appropriate. IntelliBoard has implemented physical and
technical safeguards to protect Personal Data from loss, misuse, and unauthorized
access, disclosure, alteration, or destruction. For example, electronically stored
Personal Data is stored on a secure network with firewall protection, and access to
IntelliBoard's electronic information systems requires user authentication via password
or similar means. IntelliBoard also employs access restrictions, limiting the scope of
employees who have access to Individual Customer Personal Data.
Further, IntelliBoard 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.
IntelliBoard notifies Individual Customers about its adherence to the EU-US Privacy
Shield and Swiss-US Privacy Shield principles through its publicly posted website
and take Individual customers approval and adherence to the current policy when they
provide their information to us in the transactional process.
9. Accessing Personal Data
IntelliBoard personnel may access and use Personal Data only if they are authorized to do
so and only for the purpose for which they are authorized.
10. Right To Access, Change Or Delete Personal Data
Right to Access.
Individual Customers 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 IntelliBoard collected it. Individual Customers
may review their own Personal Data stored in the databases and correct, erase, or
block any data that is incorrect, as permitted by applicable law and IntelliBoard
policies. Upon reasonable request and as required by the Privacy Shield principles,
IntelliBoard allows Individual Customers access to their Personal Data, in order to
correct or amend such data where inaccurate. Individual Customers may edit their
Personal Data by logging into their account profile or by contacting IntelliBoard by
phone or email. In making modifications to their Personal Data, Data Subjects must
provide only truthful, complete, and accurate information. To request erasure of
Personal Data, Individual Customers should submit a written request to local
Requests for Personal Data.
IntelliBoard 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 Subject. If IntelliBoard receives a request for
access to his/her Personal Data from an Individual Customer, then, unless otherwise
required under law or by contract with such Individual Customer, IntelliBoard will
refer such Data Subject to the Individual Customer.
Satisfying Requests for Access, Modifications, and Corrections.
IntelliBoard will endeavor to respond in a timely manner to all reasonable written
requests to view, modify, or inactivate Personal Data.
11. 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 available of changes to this policy either by posting to our intranet, through
email, or other means. We will notify Customers 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 manner.
12. Questions Or Complaints
EU and Swiss Individual customers may contact IntelliBoard with questions or complaints
concerning this Policy at the following address:
13. Enforcement And Dispute Resolution
In compliance with the US-EU and Swiss-US Privacy Shield Principles, IntelliBoard commits
to resolve complaints about your privacy and our collection or use of your personal
information. EU and Swiss individuals with questions or concerns about the use of their
Personal Data should contact us at:
If a Customer's question or concern cannot be satisfied through this process IntelliBoard
has further committed to refer unresolved privacy complaints under US-EU Privacy Shield
and Swiss-US Privacy Shield to an independent dispute resolution mechanism operated by
the Council of Better Business Bureaus.
If you do not receive timely acknowledgement of your complaint, or if your complaint is
not satisfactorily addressed by IntelliBoard, EU and Swiss individuals may bring a
complaint before the BBB EU and Swiss Privacy Shield program can be found at:
. Finally, as a last resort and in limited situations, EU and Swiss individuals may seek
redress from the Privacy Shield Panel, a binding arbitration mechanism.
In compliance with the Privacy Shield Principles, IntelliBoard commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact IntelliBoard at:
PO Box 474, Monroe, CT 06468
IntelliBoard has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.
14. Defined Terms
means an Individual customer or client of IntelliBoard from EU or Switzerland. The term
also shall include any individual agent, representative, of an individual customer of
IntelliBoard and all employee of IntelliBoard where IntelliBoard has obtained his or her
Personal Data from such Individual Customer as part of its business relationship with
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 Customers residing in Switzerland, a Data
Subject also may include a legal entity.
means an employee (whether temporary, permanent, part-time, or contract), former
employee, independent contractor, or job applicant of IntelliBoard or any of its
affiliates or subsidiaries, who is also a resident of a country within the European
refers to a country in the European Union.
as defined under the European Union Directive 95/46/EC 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 entity.
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 IntelliBoard nor an IntelliBoard
employee, agent, contractor, or representative.