Applied Psychological Techniques, Inc., dba APTMetrics (the “Company”), is a leading human resource consultancy providing world-class, assessment-centered talent management solutions and is nationally recognized for employment litigation support services to Fortune® 100 companies and other organizations around the world. APTMetrics delivers unparalleled service in the areas of: leadership assessment and development; hiring and promotion; litigation support and risk reduction; and talent management. These services ensure that our clients’ talent management programs are inclusive, fair, valid and legally defensible. Protecting the privacy of our clients, and the data entrusted to us, is of the utmost importance to APTMetrics.
“Personal Information” or “Information” means information that (1) is transferred from the EU to the U.S.; (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.
“Client” or “Client Organization” refers to those companies that have contracted with APTMetrics to perform consulting services on their behalf or have contracted for the use of any of the APTMetrics software as a service (SaaS) products.
Privacy Shield Principles
APTMetrics can obtain Personal Information and/or Sensitive Personal Information in many ways. It:
Use of Your Personal Information
APTMetrics will use the personal information or sensitive personal information solely to provide the services for which APTMetrics is contractually obligated to supply, to assist individuals in the use of APTMetrics products and services, or to respond to inquiries and provide related information of interest to visitors to www.APTMetrics.com that have initiated contact. We do not sell or rent your personal information to third parties.
If, in any event, APTMetrics intends to use your information for any other purpose than those stated above, you will be notified and offered the opportunity to opt out of such use.
APTMetrics may disclose personal information if required to do so by law or if we in good faith believe that such action is necessary to: (1) comply with the law or legal process; (2) protect or defend APTMetrics rights and property; (3) protect against misuse or unauthorized use of the APTMetrics Website or Web properties; or (4) protect the personal safety or property of our individual users, Clients, or the public.
Accountability for Onward Transfers
Sharing Personal Information
APTMetrics may contract with third-party providers to perform certain functions offered as part of the Company’s products and services, e.g. data center colocation services, a SaaS survey solution, and SaaS IT service management software. These providers all certify compliance with the EU-U.S. Privacy Shield Framework and are restricted from direct access to your information but, if necessary, may be granted access to your Personal Information only to the extent necessary to permit them to perform their contracted services, are bound by confidentiality agreements and are restricted from using the information for other purposes.
Links to Non-APTMetrics Websites and Third Parties
APTMetrics Websites may contain links or integration with third party sites for your convenience and/or as required to perform contracted services for its Clients. APTMetrics does not control those sites or the privacy practices of those third party sites, which may differ from the APTMetrics privacy practices detailed in this document. APTMetrics does not make any representation regarding the security or privacy of the third-party Websites and the Personal Information that you may choose to provide to any non-APTMetrics site is not covered by this policy.
APTMetrics shall take commercially reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Company has put in place appropriate physical, technical, procedural, and managerial controls to safeguard and secure personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction. APTMetrics employs a wide range of security measures including physical and logical access controls, firewalls, intrusion detection/prevention systems, security monitoring tools, endpoint protection tools, and data archival and replication strategies.
Access to personal information is restricted to those APTMetrics employees with a defined business need to know or process the information.
While APTMetrics takes commercially reasonable actions to safeguard your information, the Company cannot guarantee the security of Information on or transmitted via the Internet.
Data Integrity and Purpose Limitation
Company 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, Company shall take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.
Upon request, APTMetrics will grant individuals reasonable access to their Personal Information and allow the individual to correct, amend or delete information that is demonstrated to be inaccurate or incomplete, 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.
Recourse, Enforcement and Liability
R. Martin Kelly
Chief Compliance Officer
One Thorndal Circle
Darien, CT 06820
Or at: PrivacyShield@APTMetrics.com
APTMetrics has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacyshield/for-eu-consumers to file a complaint or obtain more information.