The U.S. Department of Commerce administers the Data Privacy Framework (“DPF”) Program, including processing submissions for self-certification and re-certification to the E.U.-U.S. DPF Principles, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles (collectively, the “DPF Principles”), and maintaining compliance with the DPF Principles..

3E will continue to participate in and comply with the relevant DPF Principles of the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

3E Company Environmental Ecological & Engineering, dba 3E (“3E”) respects your concerns about privacy. 3E complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce (collectively, the “DPF Principles”). 3E has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. 3E has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. DPF Principles with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. This Policy describes how 3E implements the applicable EU-U.S. and Swiss-U.S. DPF Principles for Consumer Personal Data. If there is any conflict between the terms in this Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the DPF Program, and to view 3E’s certification, please visit https://www.dataprivacyframework.gov/.

For more information about 3E’s processing of Personal Data obtained from Consumers on its website, please visit 3E’s Online Privacy Notice.

For purposes of this Policy:

“Consumer” means any natural person who is located in the EU or Switzerland, but excludes any individual acting in his or her capacity as an Employee.

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Customer” means any entity that purchases or otherwise obtains products or services from 3E.

“Employee” means any current, former or prospective employee of 3E, or any of its European or Swiss affiliates, who is located in the EU or Switzerland.

“EU” means the European Union and Iceland, Liechtenstein and Norway.

“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by 3E in the U.S. from the EU, United Kingdom or Switzerland, and (iii) recorded in any form.

“DPF Principles” means the EU-U.S. Data Privacy Framework Principles, the UK extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework, as may be amended from time to time. “Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.

“Swiss” means Switzerland.

 

Types of Personal Data 3E Collects

3E collects Personal Data directly from Consumers. This collection occurs, for example, when a Consumer visits 3E’s website and provides Personal Data to 3E. Click here for information on the types of Personal Data 3E receives through its website. In addition, 3E obtains Consumer Personal Data, such as contact information, in connection with maintaining its Customer relationships and providing its products and services to Customers.

As a Processor, 3E receives Personal Data about its Customers’ Consumers located in the EU and Switzerland. 3E’s Customers provide the Personal Data to 3E in connection with 3E’s provision of services to its Customers. In this capacity, 3E acts pursuant to its Customers’ instructions. The types of Personal Data 3E’s Customers provide include information such include name, postal code, email address, phone number, age general and medical and/or health information. 3E processes Consumer Personal Data in the U.S. to provide background check services.

3E’s privacy practices regarding the processing of Consumer Personal Data comply, as appropriate, with the DPF Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

 

Notice

3E provides information in this Policy and the company’s online privacy policy at http://3eco.com/privacy and about its Consumer Personal Data practices, including the types of Personal Data 3E collects, the types of third parties to which 3E discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data, and how to contact 3E about its practices concerning Personal Data.

When 3E acts as a Processor and Consumer Personal Data is transferred to 3E in the U.S. on behalf of a Customer, the Customer is responsible for providing appropriate notice to its Consumers and obtaining the requisite consent.

Privacy notices pertaining to specific data processing activities also may contain relevant information.

 

Choice

When 3E collects Personal Data directly from Consumers, the company generally offers those Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers, or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the DPF Principles, 3E obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact 3E as indicated below regarding the company’s use or disclosure of their Personal Data. Unless 3E offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy or the company’s online privacy policy at http://3eco.com/privacy.

When 3E maintains Personal Data about Consumers with whom 3E does not have a direct relationship because 3E obtained or maintains the Consumers’ data as a Processor, 3E’s Customers are responsible for providing the relevant Consumers with certain choices with respect to the Customers’ use or disclosure of the Consumers’ Personal Data.

3E shares Consumer Personal Data with its affiliates and subsidiaries. 3E may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. 3E also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

 

Accountability for Onward Transfer of Personal Data

This Policy and 3E’s online privacy policy at http://3eco.com/privacy describe 3E’s sharing of Consumer Personal Data.

To the extent 3E acts as a Controller, except as permitted or required by applicable law, 3E provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. 3E requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the DPF Principles, and (iii) notify 3E and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the DPF Principles.

With respect to transfers of Consumer Personal Data to third-party Processors, 3E (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the DPF Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with 3E’s obligations under the DPF Principles, (v) requires the Processor to notify 3E if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. 3E remains liable under the DPF Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the DPF Principles, unless 3E proves that it is not responsible for the event giving rise to the damage.

 

Security

3E takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

 

Data Integrity and Purpose Limitation

3E limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. 3E does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes and consistent with its role as a Controller or Processor, 3E takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, 3E relies on its Consumers and Customers to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers (and Customers, as appropriate) may contact 3E as indicated below to request that 3E update or correct relevant Personal Data.

Subject to applicable law, 3E retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer or Customer, as appropriate.

 

Access

Consumers generally have the right to access their Personal Data. Accordingly, to the extent 3E acts as a Controller, where appropriate, 3E provides Consumers with reasonable access to the Personal Data 3E maintains about them. 3E also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the DPF Principles, as appropriate. 3E may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting 3E as indicated below.

When 3E maintains Personal Data about Consumers with whom 3E does not have a direct relationship because 3E maintains the Consumers’ data as a Processor for its Customers, 3E’s Customers are responsible for providing Consumers with access to the Personal Data and the right to correct, amend or delete the information where it is inaccurate or has been processed in violation of the DPF Principles, as appropriate. In such circumstances, Consumers should direct their questions to the appropriate 3E Customer. When a Consumer is unable to contact the appropriate Customer, or does not obtain a response from the Customer, 3E will provide reasonable assistance in forwarding the Consumer’s request to the Customer.

 

Recourse, Enforcement and Liability

3E has mechanisms in place designed to help assure compliance with the DPF Principles. 3E conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions the company makes about its compliance with DPF Principles and privacy practices are true and that the company’s privacy practices have been implemented as represented and in accordance with the DPF Principles.

Consumers may file a complaint concerning 3E’s processing of their Personal Data. 3E will take steps to remedy issues arising out of its alleged failure to comply with the DPF Principles. Consumers may contact 3E as specified below about complaints regarding the company’s Consumer Personal Data practices.

Additionally, a Consumer may have the right to file a complaint with your local data protection or privacy agency or supervisory authority. In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, 3E commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU- U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https//www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Following the dispute resolution process, JAMS or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has DPF investigatory and enforcement powers over 3E. A Consumer has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any other of the DPF mechanisms. For additional information, please visit: Data Privacy Framework

In the context of an onward transfer, 3E has a responsibility for processing of personal information it receives under the DPF Program and subsequently transfers to a third party acting as an agent on its behalf. 3E shall remain liable under the DPF Principles if its agent processes such personal information in a manner inconsistent with the DPF Principles, unless 3E proves that it is not responsible for the event giving rise to the damage.

When 3E maintains Personal Data about Consumers with whom 3E does not have a direct relationship because 3E obtained or maintains the Consumers’ data as a service provider for its Customers, Consumers may submit complaints concerning the processing of their Personal Data to the relevant Customer, in accordance with the Customer’s dispute resolution process. 3E will participate in this process at the request of the Customer or the Consumer. If the issue cannot be resolved through the Customer’s internal dispute resolution mechanism, the Consumer may submit the complaint to the relevant data protection authority in the EEA.

 

How to Contact Us Regarding Privacy Inquiries

If you have any questions or comments about this Notice or any issue relating to how we collect, use, or disclose personal data, or if you would like us to update information we have about you or your preferences, you may contact us.

Please include your name and the name of the business, 3E, to which your request refers.

By email at: privacy@3eco.com

Write to:

3E
Attention: Privacy Team
3207 Grey Hawk Court, Suite 200
Carlsbad,
California 92029 USA

 

Our EU Representative
If you are located in the European Union (“EU”) and have any questions or comments about this Notice, any issue relating to your personal data, or if you would like us to update your preferences, you may contact our EU representative.

Please include your name and the name of the business (3E) to which your request refers.

By email at: privacy@3eco.com

3E Europe GmbH
Attention: Privacy Team
Bergheimer Str. 3
88677 Markdorf, Germany

Our UK Representative
If you are located in the United Kingdom (“UK”) and have any questions or comments about this Notice, any issue relating to your personal data, or if you would like us to update your preferences, you may contact our UK representative.

Please include your name and the name of the business (3E) to which your request refers.

By email at: datarequest@datarep.uk (quoting “3E” in the subject line)

In writing at:

DataRep
Attention: 3E – Privacy Notice
107-111 Fleet Street,
London,
EC4A 2AB
United Kingdom