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Privacy Policy: EU-U.S, Swiss-U.S. Data Privacy Policy Framework and the UK Extension to the EU-U.S. DPF

Pursuant to the EU-U.S. DPF, the EU-U.S. DPF Framework Principles have been amended as the “EU-U.S. Data Privacy Framework Principles”; and pursuant to the Swiss-U.S. DPF, the Swiss-U.S. DPF Framework Principles have been amended as the “Swiss-U.S. Data Privacy Framework Principles.

MENAINFOSEC, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and 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.  MENAINFOSEC, Inc 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 and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  MENAINFOSEC, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework 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 EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

Personal Data Collection and Use

Our Privacy Policy describe the categories of Personal Data that we may receive in the US as well as the purposes for which we use that Personal Data. MENAINFOSEC will only process Personal Data in ways that are compatible with the original purpose for which it was collected, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different from the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. MENAINFOSEC maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We may collect the following categories of sensitive Personal Data: certain information that may include your name and email address. When we collect sensitive Personal Data, we will obtain your express opt-in consent where the DPF requires, including if we disclose your sensitive Personal Data to third parties, or before we use your sensitive Personal Data for a different purpose than we collected it for or than you later authorized.

MENAINFOSEC, Inc will Inform individuals about your organization being subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Data Transfers to Third Parties

Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents, resellers, licensees, or service providers who perform functions on our behalf or on behalf of our customers as described in our Privacy Policy. Where required by the DPF, we enter into written agreements with those third-party agents, resellers, licensees, and service providers requiring them to provide the same level of protection the DPF requires and limiting their use of the data to the specified services provided on our behalf or on behalf of our customers. We take reasonable and appropriate steps to ensure that third-party agents, resellers, licensees, and service providers process Personal Data in accordance with our DPF obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents, resellers, licensees, or service providers who perform services on our behalf or on behalf of our customers for their handling of Personal Data that we transfer to them.
Third-Party Data Controllers; Limitation on Use and Disclosure. In some cases, we may transfer Personal Data to unaffiliated third-party data controllers, including our customers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your Personal Data to third-party data controllers for the purposes described in our Privacy Policy. We will only provide your Personal Data to third-party data controllers where you have opted-in to such disclosures. Any sensitive Personal Data you may have elected to provide to us is for the internal use of MENAINFOSEC only, and will not be provided to third parties at all without your express written consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data the DPF requires. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your Personal Data is protected with the same level of protection the DPF requires.

Disclosures for National Security or Law Enforcement

Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

We maintain reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the DPF.

Access Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the DPF. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances, or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information. If we have entered into a contractual agreement with a customer to administer assessments, we will refer your access request to our customer for response.

Questions or Complaints

In compliance with the DPF Principles, MENAINFOSEC commits to resolve complaints about our collection or use of your Personal Data. EU and Swiss individuals with inquiries or complaints regarding our DPF policy should first contact:


MENAINFOSEC, Inc.
651 N Broad St, Suite 206, Middletown, 19709, Delaware
ATTN: Privacy
Email: [email protected]

MENAINFOSEC has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved DPF complaints concerning data transferred from the EU and Switzerland.


We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint.
Binding Arbitration You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with MENAINFOSEC and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s DPF Framework: Annex I (Binding Arbitration).

Contact Us

If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows:
MENAINFOSEC, Inc.
651 N Broad St, Suite 206, Middletown, 19709, Delaware
ATTN: Privacy
Email: [email protected]
Changes To This Policy
We reserve the right to amend this Policy from time to time consistent with the DPF’s requirements.
Effective Date: 8 August 2023