European Union or Swiss Safe Harbor Policy

JobDiva complies 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. JobDiva 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 JobDiva’s certification, please visit http://www.export.gov/safeharbor/

JobDiva adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union ("EU") or Switzerland to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the "Principles") with respect to all such data. If there is any conflict between the policies in this European Safe Harbor Privacy Policy ("Policy") and the Principles, the Principles shall govern. This Policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This Policy applies to Personal Information (defined below) received by JobDiva whether in electronic, paper or verbal format.

Definitions

For the purposes of this Policy:

“Personal Information” or “Information” means information that (i) is transferred from the EU or Switzerland to the United States; (ii) is recorded in any form; (iii) is about, or pertains to a specific individual; and (iv) can be linked to that individual.

“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.  

Principles

Notice

JobDiva shall inform an individual of the purpose for which it collects and uses the Personal Information. JobDiva shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information (unless the disclosure is to a JobDiva service provider). Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to JobDiva, or as soon as practicable thereafter, and in any event before JobDiva uses or discloses the Information for a purpose other than for which it was originally collected.

Choice

JobDiva will offer individuals the opportunity to choose (opt out) whether their Personal Information is  to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, JobDiva will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. JobDiva shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

Onward Transfers

JobDiva does not transfer or disclose Personal Information to third parties, except to JobDiva service providers (who are only permitted to utilize such Information for the purpose for which they have been hired by JobDiva) or in the unusual circumstance that such disclosure/transfer is required by law.  In the event the transfer of Personal Information to a third party is required by law, JobDiva shall notify the affected individual of such disclosure.  

Data Security

JobDiva shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. JobDiva has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure 

Data Integrity

JobDiva shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, JobDiva shall take reasonable steps to ensure that Personal Information remains accurate, complete, current and reliable for its intended use.

Access

JobDiva shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. To correct, amend or delete your Information, please make the changes through the tools provided to you in JobDiva or contact us at contact@JobDiva.com to make such change for you.

Enforcement

JobDiva uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.  If a complaint or dispute cannot be resolved through our internal process, we agree to participate in the dispute resolution procedures of the panel established by the European data protection authority to resolve disputes pursuant to the Safe Harbor Principles.

Amendments

The practices described in this Policy are current protection policies as of December 9, 2009. This Policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on this website.

Information Subject to Other Policies 

JobDiva is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain other [or non-Personal] information is subject to policies of JobDiva that may differ in some respects from the general policies set forth in this Policy.

Contact Information

Questions, comments or complaints regarding JobDiva’s EU or Swiss Safe Harbor Policy can be emailed to SafeHarbor@JobDiva.com or mailed to:

JobDiva, Inc.
Attn: Safe Harbor
44 Wall Street
18th Floor
New York, New York 10038