EU – US Privacy Shield and Swiss – US Privacy Shield

Wigsbury respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others.

Wigsbury strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, and prides itself on upholding the highest ethical standards in its business practices.

Privacy Shield

The United States Department of Commerce and the European Commission and the Swiss Administration, respectively, have agreed on a set of data protection principles and frequently asked questions (the “Privacy Shield Framework”) to enable U.S. Companies to satisfy the requirement under European Union and Swiss law that adequate protection be given to personal information transferred from the EU and Switzerland to the United States. Consistent with its commitment to protect personal privacy, Wigsbury adheres to the Privacy Shield Principles.

Wigsbury (“we”, “us” or “our”) comply with the EU – US Privacy Shield Framework and the Swiss – US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and United Kingdom, and Switzerland to the United States, respectively.

Scope

This Privacy Shield Policy (the “Policy”) applies to all personal information received by Wigsbury in the United States from the European Economic Area and the United Kingdom, and Switzerland, respectively, in any format including electronic, paper or verbal.

Definitions

For purposes of this Policy, the following definitions shall apply:

“Personal information” means any information or set of information that identifies or is used by or on behalf of Wigsbury to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual’s health. In addition, Wigsbury will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Notice and Choice

Wigsbury enters into Service Agreements with its Clients in the European Union and the United Kingdom, and Switzerland which may include the processing and/or storage of information relating to their Clients’ customers (students, parents and staff). In these agreements, the Client agrees and recognizes that it is the ‘data controller’ for the purposes of data protection legislation. This means that our EU, UK and Swiss Clients are responsible for complying with the data protection legislation in the relevant Member State, UK and Switzerland national law before it sends its customer data to Wigsbury for processing and/or storage. This includes informing individuals about the choices and means they offer individuals for limiting the use and disclosure of their personal data. In order to exercise their rights under this principle, the individual must reach out to their School (our Client), as data controller. Any data processed or stored by Wigsbury is only disclosed to third parties at the request and direction of its European, UK and Swiss Client as the data controller, in accordance with the choices made by the individuals to whom such personal information relates, or when required by law. Any information that our EU, UK and Swiss Clients identify as sensitive will be treated as such.

Information Gathering and Usage:

Wigsbury will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

We use the information provided and that we collect to improve the content and quality of the Service, error correction, improving our marketing, and for administrative purposes.

Your use of the Service results in collection of audit log records, which are collected through third party solutions. These facilitate providing the Service, through web hosting companies or by using analytics providers. This allows us to monitor system and application performance, to track usage activity and to enable our support team to provide you with a professional standard of service when you have any issue.

If it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Service or Terms of Use, or to comply with any legal requirement such as, but not limited to, complying with a subpoena or cooperating with law enforcement agencies.

Access Personal Data

If your personal information changes, you are able to login to keep it up to date by changing your profile. If you no longer wish to receive the Service or if you find that information on the Website is not accurate and you cannot update it, please inform contact us.

Client Data Storage:

ManageBac complies with the EU – US Privacy Shield Framework and the Swiss – EU Privacy Shield Framework as set forth by the Department of Commerce regarding the collection, use, and retention of data from the European Union, United Kingdom, and Switzerland.

If you have any questions, comments, or concerns or wish to update, delete or change any personal information submitted on this Site, or have any questions about our Privacy Policy, please contact

Changes To This Privacy Shield Policy

This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles.

Effective Date: January 1st, 2021

Updated at January, 10th, 2021

Reference:

To learn more about the EU – US Privacy Shield Framework and Swiss – US Privacy Shield Framework. https://www.privacyshield.gov/