We self-certify compliance with:

Enginologi, Inc. (“Enginologi”) is globally positioned to receive and collect personal information from individuals in the USA, the European Union (“EU”) and Switzerland. Enginologi has established a robust data privacy program with a strict view towards the protection of your data privacy rights.

Enginologi (a U.S. and Swiss company) complies with the U.S.–E.U. 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 data from our subsidiaries, corporate customers, and other business partners in the European Union member countries and Switzerland. Enginologi 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 the certification for Enginologi, Inc., please visit http://www.export.gov/safeharbor.

Description of Activities

Enginologi anticipates receiving and collecting personal information from individuals in the European Union (“EU”) and Switzerland. Enginologi has established a comprehensive privacy program that has been designed to and is intended to protect your data privacy rights.

Enginologi adheres to the Safe Harbor Agreement concerning the collection, transfer, and use of personal data from the EU to the United States of America (“US”) and the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce. With respect to such personal information, Enginologi follows and adheres to the Safe Harbor Principles published by the U.S. Department of Commerce (“Principles”), and the 15 Frequently Asked Questions concerning all such personal information, including its collection, use, and retention of personal information from EU member countries and Switzerland. The Principles are: Notice, Choice, Onward Transfers, Access, Security, Data Integrity, and Enforcement. The terms “personal information,” “information,” and “sensitive personal information” as used herein have the same meaning as used defined in the Safe Harbor Program. Again – to learn more about the Safe Harbor Program and to view our certification page, please visit http://www.export.gov/safeharbor.

1. Notice: If Enginologi collects personal information from individuals in the EU or Switzerland, it will advise them about the purposes for which the information is collected and used, the types of third parties to whom Enginologi shares the information, if any, the ability of the users to limit the use and disclosure of such information, and how to contact Enginologi. Enginologi will provide notice in clear and conspicuous language at the time such information is collected by Enginologi or as soon as practicable thereafter and, at all times, before Enginologi uses or discloses the information for a purpose other than which it was originally collected. When Enginologi receives personal information from other entities in the EU or Switzerland, it will use and disclose such information consistent with the notices provides by such entities and the choices made by the individuals from whom the information was collected.
2. Choice: Enginologi will provide individuals with the choice of whether the personal information is to be disclosed to a non-agent third party or used for a purpose other than that for which it was originally collected or subsequently authorized by the individual. For sensitive personal information, Enginologi will provide individuals with the opportunity to affirmatively or explicitly consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than that which it was originally collected or subsequently authorized by the individual.
3. Onward Transfers: Enginologi will not disclose personal information to third parties unless such disclosure is permissible pursuant to applicable law and regulations and only if the third party operates in a manner pursuant to this policy and/or the Safe Harbor Agreements and Principles and provides the same level and degree of privacy protection as established in this Privacy Policy and agrees in writing to provide an adequate level of privacy protection.
4. Access: Enginologi will provide individuals with reasonable access to information it has about them upon their request, and Enginologi will take reasonable measures to allow for the correction, amendment, or deletion of information that is shown to be incorrect or inaccurate. Regarding this, email Enginologi at: [email protected].
5. Security: Enginologi maintains various safeguards, including physical and electronic and managerial procedures, to protect the security and confidentiality of personal information that it has received. Enginologi takes reasonable precautions to protect against unauthorized access, misuse, disclosure, destruction, or alteration of data in its control.
6. Data Integrity: The personal information uses or processes will be necessary for and related to the purpose for which it was obtained or collected. Enginologi will not use or process the data in a manner that is inconsistent with the reason it was collected or authorized to be used. Enginologi will take reasonable measure to ensure that the data is accurate, complete, current, and reliable for its intended use.
7. Information collected by Enginologi subsidiaries (if any), corporate customers and business partners.
8. Enforcement: Enginologi is committed to monitoring and ensuring compliance with this policy and relevant privacy laws and regulations. Enginologi maintains strict confidentiality and security policies with respect to all information it receives that applies to all of its personnel. All personnel are made aware of these policies, and Enginologi has procedures in place for personnel to be trained on all of these policies. If an employee fails to adhere to Enginologi’s policies, the employee is subject to discipline. Enginologi has established a mechanism to conduct reviews of its policies, including their effectiveness and internal compliance with the policies.

This Privacy Policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy online on this website.

In compliance with the US-EU and US-Swiss Safe Harbor Principles, Enginologi commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Enginologi at: Enginologi, Inc. 136 Ridge Avenue, Newton MA 02459, USA, attn: Markus Hauser, at [email protected]. Any complaints regarding this Privacy Policy will be investigated, with the goal of resolving the complaint to the satisfaction of all parties.

Enginologi has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, JAMS.