Privacy Shield

Privacy Shield Statement
OmniPoint US, LLC (hereinafter collectively referred to as the “OmniPoint,” “OmniPoint Staffing,” “we,” “us” or “our”) complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland, to the United States in reliance on Privacy Shield. OmniPoint has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Definitions
“Personal Information” or “Information” means information that (1) is transferred from the European Union, United Kingdom, and Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) 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 OmniPoint shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which OmniPoint discloses or may disclose that Information. OmniPoint shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to OmniPoint, or as soon as practicable thereafter, and in any event before OmniPoint uses or discloses the Information for a purpose other than for which it was originally collected.

Choice
OmniPoint will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) 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, OmniPoint 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. OmniPoint 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
Prior to disclosing Personal Information to a third party, OmniPoint shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. OmniPoint shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.

Data Security
OmniPoint shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. OmniPoint 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. OmniPoint cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity
OmniPoint 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, OmniPoint shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access
OmniPoint 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.

Enforcement

OmniPoint US, LLC
Attention: Derek Shipes
14707 S Dixie Hwy, Suite 201
Miami, FL 33176
Phone: 813.987.3756
Email: derek.shipes@omnipointstaffing.com

OmniPoint has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved EU Privacy Shield complaints, including concerning both human resources data and non-human resources data transferred from the EU.  If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint.  The services of EU DPAs are provided at no cost to you.​

OmniPoint has further committed to cooperate with the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Swiss Privacy Shield complaints, including concerning both human resources data and non-human resources data transferred from Switzerland. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the FDPIC for more information or to file a complaint  https://www.edoeb.admin.ch/kontakt/index.html?lang=en

OmniPoint has further committed to comply with Privacy Shield with regard to personal data received from the UK and that has committed to cooperate and comply with the EU Data Protection Authority panel under the Framework will be understood to have committed to cooperate and comply with the UK Information Commissioner’s Office (ICO) with regard to personal data received from the UK in reliance on Privacy Shield.

As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. OmniPoint is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). ​

OmniPoint is committed to the lawful treatment and confidential handling of sensitive information, including personal information about California residents, and has adopted a set of global information management policies including privacy and data protection, security, system access, information classification, and other relevant policies governing the collection, use, disclosure, transfer, retention, and deletion of information.

OmniPoint as a “Service Provider” (as defined in the CCPA) confirms that it will process personal information which it retains, uses, or discloses in connection with its performance under any contract: (1) only on behalf of and for the benefit of the “Business” (as defined in the CCPA) from which it has received the personal information; (2) only in accordance with the contract and Business’s prior written instructions, if any; unless (3) as otherwise required by the CCPA. OmniPoint confirms that it will not process personal information for any purpose other than for the specific purpose of performing the services specified in the contract.

Personal Information OmniPoint Processes

Data Collected via our Website
For each visitor to our Web page, our Web server may use a tracking code or collect information that your browser sends whenever you visit our Web page. This information is aggregated to provide us with usage statistics and reports on Website visits.  On the “Contact Us” section of our Website, we collect Personal Information that includes name, email address, and phone number.  We use this information to contact you for employment or sales opportunities.  When you provide us with your contact information, you consent to allow us to contact you for those purposes.  This information is not shared with other organizations.

Data Processed on behalf of our Customers
OmniPoint is an IT Staffing firm focused on supporting our Customers IT initiatives.  In the course of providing these services, OmniPoint may process data, including Personal Information and HR Information, on behalf of its customers.  In this context, OmniPoint acts as a data processor and does not control the data. OmniPoint processes Customer Data under the explicit direction of its Customers and has no direct control or ownership of the personal data it processes. Customers are responsible for complying with any regulations or laws that require providing notice, disclosure and/or obtaining consent prior to transferring the data for processing purposes.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his or her query to the OmniPoint Customer (the data controller). If the Customer requests OmniPoint to remove the personal data to comply with data protection regulations, OmniPoint will respond to their request within 30 business days.

Onward Transfer of Personal Data
OmniPoint does not transfer any Personal Data we collect directly to third parties or other partners.  This data is used for communication with our contacts and kept internally within OmniPoint.

Upon explicit direction from our Customers, we will transfer Customer Personal Data to service providers that support the Customer.  These service providers may include cloud service providers, such as Workday, or other service providers such as benefits administration partners.  All of these transfers are processed within the scope of our services for our Customers.

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

OmniPoint is under the requirement to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

OmniPoint will notify Customer of such request unless prohibited by law.

AmendmentsThis privacy policy may be amended from time to time consistent with the requirements of the Swiss-US Privacy Shield Framework and EU-US Privacy Shield Framework. We will post any revised policy on this website.

Please contact the following with any questions regarding this policy:

OmniPoint US, LLC
Attention: Glenn Myer
14707 S Dixie Hwy, Suite 201
Miami, FL 33176
Phone: 813.503.2975
Email: glenn.myer@omnipointstaffing.com

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