EU-US Privacy Shield Policy — Enterprise Health

Enterprise Health is a division of Medical Informatics Engineering, Inc. Enterprise Health provides a software solution to its customers, which enables those customers to manage the health and wellness of their employees and to maintain compliance with occupational health regulations. Enterprise Health is not a data controller for the purposes of the Data Privacy Frameworks. Instead, Enterprise Health is a data processor. As such, many of the provisions of the Data Privacy Framework may be inapplicable to Enterprise Health.

As a data processor, Enterprise Health complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Enterprise Health has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Enterprise Health has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

ENFORCEMENT AUTHORITY

With respect to personal data received or transferred pursuant to the Data Privacy Frameworks, Enterprise Health is subject to the regulatory and enforcement powers of the US Federal Trade Commission.

SUBSIDIARIES OR AFFILIATES

Enterprise Health is a fully-owned subsidiary of Medical Informatics Engineering, which also adheres to the Data Privacy Principles.

DATA COLLECTED

On behalf of our clients, Enterprise Health stores, processes, and transmits protected health information as defined by the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule. Depending upon the data collected by our clients, the protected health information may include an individual's past, present or future physical or mental health conditions and medical test results. Personally identifiable information, such as name, social security number or date of birth, may also be collected by our clients. Enterprise Health does not control or collect any data directly from individuals.

THIRD PARTIES & LIABILITY

Enterprise Health does not disclose personal information to third parties, whether acting as agents or controllers. If this policy should change in the future Enterprise Health will update this posted policy and will provide individuals with a choice regarding the sharing of their personal data. In the event that Enterprise Health transfers personal information to a third party acting as an agent on its behalf, Enterprise Health will remain responsible and liable under the Data Privacy Framework Principles if the agent processes the data in a manner inconsistent with the Principles, unless Enterprise Health proves that it is not responsible for the event giving rise to the damage.

ACCESS AND UPDATE DATA

Enterprise Health acknowledges the individual's right to access their personal data. Individuals who wish to access, correct or delete their personal data should consult with the data controller of their personal information. Individuals who wish to limit the use or sharing of their data should also contact the data controller of their information. In both of the above cases, this would most likely be the individual's employer or former employer who contracts with Enterprise Health to provide data processing services.

LIMITING USE AND DISCLOSURE

Enterprise Health reserves the right to share personal information and to disclose it to others to the extent permitted or required by law, to investigate potential wrongdoing, or to protect the rights, property or safety of Enterprise Health or others.

DISCLOSURE OF PERSONAL INFORMATION

Enterprise Health may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

CONTACT FOR INQUIRIES OR COMPLAINTS — NON-HUMAN RESOURCES DATA

European Union, United Kingdom and Swiss individuals should contact their employer or other organization directly in order to address questions or comments or make requests regarding the handling of their non-HR data.

In compliance with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) Principles, Enterprise Health commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact:

Enterprise Health
Attention: Doug Horner, CEO
1690 Broadway, Suite 550
Fort Wayne, IN 46802
horner@enterprisehealth.com

DISPUTE RESOLUTION

Enterprise Health has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

BINDING ARBITRATION

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

HUMAN RESOURCES DATA WITHIN THE WORKING RELATIONSHIP

Contact for inquiries or complaints:

European Union, United Kingdom and Swiss individuals should contact their employer directly in order to address questions or comments or make requests regarding the handling of their HR data.

In compliance with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and Swiss-US Data Privacy Framework (Swiss-US DPF) Principles, Enterprise Health commits to resolve complaints about your privacy and our collection or use of your personal information as a data processor.

European Union, United Kingdom and Swiss individuals with questions, comments or requests regarding Enterprise Health processing of their data, if any, should contact Enterprise Health at: