Genius SIS, Inc. Privacy Shield

 

Genius SIS, Inc. complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information received from the European Union. Genius SIS have certified that they adhere to the Privacy Shield principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability (“Principles”). If there is any conflict between the policies in this Statement and the Privacy Shield Principles, the Principles shall govern. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website: https://www.privacyshield.gov/. For more information regarding our Privacy Shield certification, please see: https://www.privacyshield.gov/list.


1.Scope

This Policy applies to any personal information received by Genius SIS from the European Union in reliance on Privacy Shield.


2.Collection and Use of Personal Data

Genius SIS provides Student Information System solution to its Customers, which are predominantly schools and business customers. Genius SIS collects Personal Data from Customers when they register on our system, log-in to their account, request information from us, or otherwise communicate with us. The Personal Data that we collect may vary based on the Customer's needs. As a general matter, Genius SIS collects the following types of Personal Data from its customers: contact information, including, a contact person’s name, last name and email. Genius SIS requests personal information to operate, maintain and provide the features and functionality of the Services provided and to communicate, as well as for purposes such as the provision of customer service and support, billing, and other exchanges of information. The personal information supplied to Genius SIS will not be given, sold, rented, loaned, or otherwise disclosed to any third parties outside of Genius SIS and its employees, except when we have permission or under special circumstances, such as when that disclosure is reasonably necessary to (i) comply with legal process, (ii) enforce the Terms of Use, (iii) respond to claims that any content provided by using the Services violates the rights of third parties, or (iv) protect the rights, property, or personal safety of Genius SIS, its users, or the public.


3.Right to Access Personal Data

EU individuals have the right to reasonable access to the personal information that we hold. On request, we will also take reasonable steps to correct, update, amend or delete any information that is demonstrated to be inaccurate, except where the burden or expense of doing so would be disproportionate to the risks to your privacy in the case in question or where the rights of third parties would be violated. Where we process personal information on behalf of an Institution, we will direct any individual requests for access or to limit use or disclosure to the Institution, and we will work with such Institution in complying with such requests in accordance with applicable law and our obligations under Privacy Shield.


4.Data Integrity and Purpose Limitation

Genius SIS will process personal information in a manner that is compatible with and relevant to the purpose for which it was collected or authorized by individuals. Where we receive personal information from an Institution, it shall be the Institution that determines those purposes. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.


5.Jurisdiction and Enforcement

As part of participating in Privacy Shield, Genius SIS is subject to the investigatory and enforcement powers of the US Federal Trade Commission.


6.Lawful Requests

Genius SIS may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


7.Transfers to Third Parties

Genius SIS may transfer personal information to certain third parties. Where Genius SIS transfers personal information to a third party, will take reasonable and appropriate steps to ensure the third party processes personal information for limited and specified purposes and in a manner consistent with Genius SIS’s Privacy Shield obligations. Where the transfer is to a third-party agent acting on our behalf, Genius SIS may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage.


8.Complaints Mechanism

In Compliance with the Privacy Shield Principles, Genius SIS commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Genius SIS at info@geniussis.com. Genius SIS has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, of if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you.


9.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 complaint directly with Genius SIS 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. Please see the Privacy Shield website for further information: https://www.privacyshield.gov/article?id=C-Pre-Arbitration-Requirements