Privacy Policy

Visitors to the www.IntegrationPoint.com website may either request information on Integration Point products or download white papers on topics of interest by submitting information such as name, title, company, phone number, e-mail address, the region in which the visitor is located and Integration Point products in which the visitor may be interested. Integration Point uses this information (1) to provide relevant marketing materials and facilitate the sales and contracting process for Integration Point products and services; and (2) to provide notices of events, seminars, webinars, whitepapers and conferences.

SAFE HARBOR

Safe Harbor Program
In order to bridge the gap between the United States (the “US”) and the European Union (the “EU”) regarding privacy and to provide an adequate means for US companies to comply with the European Commission’s Directive on Data Protection (the “Directive”), the US Department of Commerce, in consultation with the European Commission, developed the US-EU Safe Harbor Program. Companies can qualify for the Safe Harbor Program by complying with seven privacy principles (the “Principles”).

Scope
This Safe Harbor Policy (the “Policy”) applies to all electronic and written Personal Information that Integration Point receives in the US from any of the 27 EU member countries. This Policy does not apply to the Personal Information of Integration Point employees. The Notice, Choice and Onward Transfer provisions of this Policy do not apply to public record information or publicly available information so long as such information has not been combined with non-public Personal Information.

Definitions
“Agent” means any third party (e.g., subcontractors) that - on behalf of Integration Point - accesses, uses or maintains Personal Information that is received by Integration Point.

“Integration Point” means Integration Point, Inc.

"Personal Information" means information that identifies or could be used by or on behalf of Integration Point to identify an individual in the EU. Personal Information does not include information that is encrypted, encoded or that is made anonymous.

Categories of Personal Information
Integration Point provides global trade management and compliance solutions to corporate clients. Unless a client is operating as a sole proprietor, Integration Point would not typically provide such solutions to individuals. Consequently, Personal Information that Integration Point receives from the EU is primarily in the form of contact or identifying information for either employees of an Integration Point client or a client’s customers, subcontractors, agents, trade partners, vendors, etc.

Privacy Principles
Integration Point complies with the US-EU Safe Harbor framework and has certified its adherence to the Principles as follows:

  1. Notice.
    • Clients and Prospective Clients
      1. Sales - Integration Point may collect Personal Information from clients and prospective clients during the product sales cycle, when such information is submitted to Integration Point through its website at www.IntegrationPoint.com, or when a whitepaper on a topic of interest is downloaded from the Integration Point website. This Personal Information may be maintained by Integration Point sales, legal and/or marketing representatives, and this information may also be stored in the contact management system of a third-party vendor. Integration Point will take reasonable steps to ensure that any such third-party vendor is in compliance with the EU Safe Harbor Framework. Personal Information collected by Integration Point through the means described above is used to (1) facilitate the sales and contracting process; (2) invoice clients; (3) notify clients or prospective clients of events, seminars, webinars, whitepapers, conferences, etc. of potential interest; and (4) provide clients or prospective clients with marketing materials for Integration Point products and services.
      2. Conferences; Webinars – Integration Point may collect Personal Information from the registrants and attendees of conferences, seminars, webinars, etc. hosted or attended by Integration Point. This Personal Information is used by Integration Point to (1) communicate with the registrants leading up to the conference; (2) notify the registrants and attendees of future events, seminars and conferences of potential interest; (3) inform the registrants and attendees about Integration Point products and services; and (4) provide clients or prospective clients with marketing materials for Integration Point products and services.
      3. Implementation and Support - Integration Point may collect Personal Information from clients during the implementation and support periods. This Personal Information is used by Integration Point for project communication, ongoing support purposes and alerts related to Integration Point products.
      4. Use of Integration Point Modules - Clients who have been implemented on the Integration Point system may input Personal Information into the Integration Point system. This Personal Information is maintained by Integration Point and is used to facilitate business functions on behalf of the client (including, but not limited to, transmitting select Personal Information to the client’s trade partners and government agencies) and to fulfill any applicable contractual obligations to the client. Integration Point may also collect a client’s IP address during the client’s use of an Integration Point module. This information is used to identify the geographic region from which the client is accessing the module.
    • Service Providers, Vendors and Prospects - Integration Point may collect and maintain the Personal Information of service providers, vendors and prospective service providers and vendors. This information is used for the purposes of communication, evaluation, product and services acquisition (including real property leases and product licenses), and for making payment for such products and services.
    • Government Agencies – In working with the government agencies of the EU member countries, Integration Point may receive the Personal Information of employees or representatives of such government agencies. This Personal information is used to communicate with those employees or representatives.
  2. Choice. Except as otherwise specified herein, Integration Point will not provide Personal Information to any third party or use Personal Information for any purpose other than that for which the Personal Information was originally collected without the prior written consent of that person or entity. Integration Point will give the person or entity an affirmative opt-out choice if the Personal Information is to be disclosed to a third party or used for a purpose other than the purpose for which it was collected or for which its use was otherwise authorized by the client or prospective client.
  3. Onward Transfers. Integration Point will comply with the Notice and Choice provisions of this Policy in disclosing Personal Information to a third party. If Personal Information is transferred to a third party acting as an Agent for Integration Point, Integration Point will first confirm that the third party subscribes to the Principles or is subject to the Directive or another adequacy finding. If the third party is not, Integration Point will enter into an agreement with the third party to require the third party to provide at least the same level of privacy protection as is required by the relevant Principles.
  4. Access. Integration Point will take reasonable steps to enable inaccurate Personal Information to be corrected, amended or deleted, except where the burden or expense of doing so would be disproportionate to the risks to an individual’s privacy in the case in question or where the rights of persons other than the individual would be violated.
    • Clients
      1. Sales Data - Clients have the option of confirming the accuracy of Personal Information that was collected during a sales cycle by contacting either the sales person with whom they worked during the sales cycle or Integration Point at This email address is being protected from spambots. You need JavaScript enabled to view it.. If inaccurate, clients can request that their Personal Information be corrected, amended, or deleted.
      2. System Data – Personal Information that has been entered into the Integration Point system by a client while using an Integration Point module may be accessed and modified by the client.
    • Vendors - Vendors have the option of confirming the accuracy of their Personal Information by contacting the Integration Point Accounting Department at This email address is being protected from spambots. You need JavaScript enabled to view it.. If inaccurate, vendors can request that their Personal Information be corrected, amended, or removed.
  5. Security. Integration Point will take reasonable precautions to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction.
  6. Data Integrity. Integration Point will not process Personal Information in a way that is incompatible with the respective purposes for which it has been collected or subsequently authorized by a client or vendor, as applicable.
  7. Enforcement: Integration Point will conduct an internal compliance review of this Policy as a part of an annual audit process. If integration Point determines that an employee has intentionally violated this policy, the employee will be subject to disciplinary action up to and including termination of employment.
  8. Dispute Resolutions: Concerns regarding the use of Personal Information should be directed to Integration Point’s Legal Department at the address provided below. Integration Point will investigate and attempt to resolve complaints and disputes regarding use of Personal Information in accordance with the Principles. For complaints that cannot be resolved between Integration Point and a complainant, Integration Point has agreed to participate in the dispute resolution procedures of JAMS.

Limitation on Application of Principles
Integration Point’s adherence to the Principles may be limited to the extent permitted by applicable regulation, rule or law or as required by court order.

Contact
Inquiries regarding this Policy shall be submitted by mail or e-mail to Integration Point at the following addresses:

Attn. Counsel
Integration Point, Inc.
10720 Sikes Place, Suite 300
Charlotte, NC 28277

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Policy Amendments
This Policy may be amended from time to time by Integration Point in its discretion. Integration Point will provide notice of substantive amendments.

Safe Harbor Program Website
To learn more about the Safe Harbor program, and to view Integration Point’s certification, please visit http://www.export.gov/safeharbor/.

Effective Date: May 1, 2012
Last Amended: May 7, 2014