Orion System Integrators LLC. and its affiliated U.S. entities (collectively, “Orion,” “we,” “us,” and “our”) adhere to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework published by the U.S. Department of Commerce (“Principles”, “Privacy Shield” or “Privacy Shield Program”).

This Statement outlines the general policies and practices that Orion has adopted towards implementing the Privacy Shield Framework, including details on the types of personal data that the firm gathers, how that information is used, the options available to individuals affected by our use of such information, and the options available to them to correct personal data relating to them. If there is any conflict between what is described in this statement and the Principles, the Principles will govern.

This Statement applies to European Union non-HR and HR data and Swiss non-HR and HR data transferred under the Privacy Shield Framework from member countries of the European Union and Switzerland to Orion’s various operational centers in the U.S.  It does not apply to Personal Data that is transferred under other mechanisms, such as Standard Contractual Clauses. To learn more about the Privacy Shield Programs and to view Orion’s certification, please visit:

https://www.privacyshield.gov/list.

Under the Privacy Shield Program, individuals have the right to access the personal data that Orion has about them. Individuals wanting to access the data will have to provide identification details such as name, address, date of birth etc. Additional information may be called for, such as a national identifier (e.g. Social Security Number) as a further precautionary measure. Orion may limit or deny access to personal information under circumstances where providing such access would be unreasonably burdensome or overly expensive, or where it would be detrimental to the rights of people other than the individual seeking access.

European Union and Swiss Persons may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website.

Please email us at [email protected] if you feel you need to correct, modify, or delete inaccurate information, or information that has been obtained in contravention of the principles of the Privacy Shield Program. Storage of personal data collected will be as per Orion’s data retention requirements and corporate policies.

Personal data collected will be processed and used solely for the purpose for which it was originally collected or authorized to be collected by the individual. We will take all reasonable steps to ensure that the data so collected is correct, complete, current and reliable regarding its intended use.

Various physical, logical, and policy measures are used to protect personal data from loss, misuse or unauthorized access, disclosure, alteration or destruction. Personal information displayed on websites will be protected by standard encryption processes.

Orion has put processes and practices in place to monitor compliance with requirements under the Privacy Shield Program, and to address queries and concerns regarding compliance.

Complaints regarding Orion’s processing of personal data under the Privacy Shield Program may be addressed to [email protected]. The following options are available to address disputes relating to Orion’s privacy policy that cannot be resolved through our internal processes: 

• If the dispute relates to personal data collected in the context of an employment relationship, Orion will work with EU Data Protection Authorities, which serves as an Independent Recourse Mechanism for HR data covered by privacy shield. If it is determined that Orion has failed to comply with the terms of the Privacy Shield Program, appropriate steps will be taken to address the fallout of such non-compliance, and to ensure there is no recurrence of the same.
• If the dispute relates to other types of data, individuals are free to approach EU Data Protection Authorities or Swiss Federal Data Protection and Information Commissioner

Personnel working for Orion who violate our privacy policies will face disciplinary action.

Orion does not transfer data to third parties outside of its agents. Orion will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant EU-US Privacy Shield and Swiss-US Privacy Shield Principles or being subject to another European Commission adequacy finding. Where Orion has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Orion will take reasonable steps to prevent or stop the use or disclosure. Orion is liable for appropriate onward transfers of personal data to third parties who do not comply with the Privacy Shield principles.

Please be aware that Orion may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Orion participation in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework is subject to investigation and enforcement by the Federal Trade Commission.

In compliance with the Privacy Shield Principles, Orion commits to resolve complaints about your privacy and our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding this Privacy Shield Policy should first contact Orion at: [email protected].

Orion will satisfy the requirement of this Principle through the following:

Compliance with legal or regulatory supervisory authorities that provide for handling of individual complaints and dispute resolution; and Commitment to cooperate with (DPA) data protection authorities located in the EU, and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data and non-human resources data transferred from the EU and Switzerland.

Under certain conditions detailed in the Privacy Shield, Data Subjects may be able to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

Orion agrees to periodically review and verify its compliance with the Privacy Shield Principles, and to remedy any issues arising out of failure to comply with the Privacy Shield Principles. Orion acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Privacy Shield participants.

This Privacy Shield Policy may be amended from time to time consistent with the requirements of the Privacy Shield Program. Appropriate notice will be given regarding such amendments.