Date last revised: 10/07/2014
- addresses our European Union/Swiss - U.S. Safe Harbor Privacy statement;
- addresses our Website Privacy Statement, which applies to our Internet websites located at http://www.inin.com and http://debtsoftware.com or any successor Internet websites thereto (the “Sites”);
- describes the privacy principles followed by Interactive Intelligence with respect to transfers of Personal Data (defined below) from the European Economic Area and from Switzerland to the United States; and
- outlines our practices for collecting, using, maintaining, protecting and disclosing that Personal Data.
Definitions used in this policy
Data Protection Directive: EU Directive 95/46/EC on the protection of individuals with regard to the processing of personal data and on the free movement of such data.
Agent: any third-party data processor that processes personal data provided by Interactive Intelligence on its behalf and under its instructions.
Personal Data: any information or set of information that identifies or could be used to identify (together with other information) a living individual. Personal Data does not include information that is anonymized or aggregated.
Safe Harbor Principles: the safe harbor principles agreed between the United States Department of Commerce and the European Commission.
Sensitive Personal Data: any Personal Data that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information that concerns health or sex life, and information about criminal or administrative proceedings and sanctions
- What personally identifiable information (Personal Data) is collected from you and how will it be used?
- How can you restrict the use of your information?
- What steps will we take before transferring your information to third parties?
- How can you access or correct information held about you?
- How will your information be protected?
- What information may be gathered from children?
- What are cookies and how are they used?
- How will we ensure compliance with this policy?
- What is the Interactive Intelligence Safe Harbor Policy?
What personally identifiable information is collected from you and how will it be used?
In general, you can visit our Sites without telling us who you are or revealing any Personal Data about yourself. In fact, we encourage anonymous surfing so that you can find out more about who we are and how our products can help streamline business communications and other processes. However, there are times when we may need and request Personal Data from you so that we can better serve you.
Interactive Intelligence will only collect Personal Data (such as your name, address, telephone number, or email address, employer name, employer address or products and operating systems you use) when it is voluntarily submitted to us at the Sites. We will use this information to comply with your request for information or as otherwise disclosed to you at the location on the Sites at which you submit your information. For example, if you request technical support assistance, we need to know who you are, what product you are using and in what computer system environment you are using the product in order to respond to your request as efficiently and effectively as possible. If you are interested in signing up for one of our Webinars, the Personal Data you provide to us will enable us to tailor the Webinar more closely to your specific needs. Also, when you request a product download from the Sites, we want to be able to follow up with you to address any questions you might have about using our products. In addition, from time to time, we may refer to your Personal Data to better understand your needs and how we can improve our products and services. We may use that information to contact you.
We will not sell or otherwise transfer the Personal Data you provide via the Sites to any third party unless (1) otherwise disclosed to you when you submit your information; (2) in connection with the sale of all or substantially all of the assets of a business division of Interactive Intelligence, a line of Interactive Intelligence’s business or Interactive Intelligence’s entire business or merger with another company; (3) to provide needed information to our Agents, resellers, partners and contractors who may provide products and/or services to you; (4) as necessary for processing your credit card transactions or support transactions; or (5) for compliance with possible legal or governmental disclosure requirements. We do not rent, sell or otherwise share information that we gather about our website visitors with outside parties. The bottom line is that all the information that you provide to us via the Sites will remain with Interactive Intelligence and/or its Agents, resellers, contractors and alliance partners.
The Sites use information in aggregate form to track the total number of visitors to our, the number of visitors to each page of our Sites, and the domain names of our visitors' Internet service providers. No Personal Data is revealed to us in this process.
How may you restrict the use of your information?
We will provide you with the opportunity to opt out of any disclosure of your Personal Data to any third party that is not our Agent or the use of that data for a purpose other than the purpose for which it was originally collected from, or subsequently authorized by, you.
We will not disclose Sensitive Personal Data to a third party that is not our Agent or use Sensitive Personal Data for a purpose other than the purpose for which it was originally collected from, or subsequently authorized by, you unless we have received your affirmative and explicit consent to do so (opt-in).
For additional information regarding how you may restrict the use of your Personal Data please contact us at firstname.lastname@example.org.
Appropriate assurances may include:
- we may require our Agent to enter into a contract with us that requires the Agent to provide at least the same level of protection as is required by the Safe Harbor Principles;
- in certain circumstances, our Agent may be subject to the Data Protection Directive;
- our Agent may be established in a country that is subject to a finding of adequacy by the European Commission under Article 25(6) of Data Protection Directive; or
- our Agent may have their own safe harbor certification.
How can you access or correct information held about you?
Upon request, we will provide you with reasonable access to the Personal Data that we hold about you except where the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated by the provision of such access.
We will take reasonable steps to enable you to correct, amend or delete Personal Data related to you in our possession and control that is inaccurate or incomplete.
How will your information be protected?
Interactive Intelligence is committed to protecting the Personal Data entrusted to us. We have implemented appropriate physical, electronic and administrative procedures to safeguard and secure this information from loss, misuse, unauthorized access or disclosure, alteration and destruction.
We will take special care to ensure the security of Sensitive Personal Data. We will use Personal Data only in a way that is compatible with and relevant to the purpose for which it was collected or authorized by you or for other compatible purposes.
To the extent necessary for those purposes, we will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, current and reliable for its intended use
What information may be gathered from children?
The Sites are not intended or designed to attract children under the age of 13. Interactive Intelligence does not collect personally identifiable data from any person it knows to be under the age of 13.
What are cookies and how are they used?
Some pages within the Sites may use a technology called "cookies". A cookie is a token that a server gives to your browser when you access an Internet website. Cookies are capable of storing many types of data. Cookies help provide additional functionality to the Sites or to help us analyze site usage more accurately. In all cases in which cookies are used, the cookie will not collect Personal Data except with your explicit permission.
Any questions or concerns regarding our use or disclosure of Personal Data should be addressed to the Interactive Intelligence legal department at the address given below.
For Personal Data relating to employees, consumers, customers, and investors that is transferred to Interactive Intelligence from the European Economic Area and/or Switzerland, Interactive Intelligence has committed to handling such personal information in accordance 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.
The Safe Harbor Principles enable Interactive Intelligence to satisfy the EU requirement set out in the EU Data Protection Directive that personal information transferred from the EEA to the United States be adequately protected. Interactive Intelligence 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 our certification, please visit http://export.gov/safeharbor/.
Changes to this Safe Harbor Policy
We encourage you to contact us to inform us of any complaints or disputes you may have regarding the use of your Personal Data. We will investigate the matter and attempt to resolve the issue quickly.
If your dispute cannot be resolved by us internally, we agree to dispute resolution with the EU and Swiss data protection authorities (DPAs). We will cooperate with the DPAs in the investigation and resolution of complaints brought under the Safe Harbor and we agree to comply with any advice given by the DPAs where the DPAs take the view that the organization needs to take specific action to comply with the Safe Harbor Principles.