Privacy Policy
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The purpose of this Privacy Policy is to describe the practices employed by Asentinel LLC with respect to the acquisition, receipt, use, and protection of the information we receive from and on behalf of our corporate clients, prospects, and partners. The United States Department of Commerce and the European Commission have designed a framework called the EU-U.S. Privacy Shield to provide companies with a mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States in support of transatlantic commerce. Asentinel 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 from European Union member countries. Asentinel has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. Asentinel also continues to comply with the U.S.-Swiss Safe Harbor Framework and its principles, which will not be affected by our commitment to the EU-U.S. Privacy Shield Framework. For more information concerning the EU-U.S. Privacy Shield Framework and to view Asentinel’s certification please visit www.privacyshield.gov. For more information concerning the U.S.-Swiss Safe Harbor Framework and to view Asentinel’s certification, please visit safeharbor.export.gov.

Information Collected and Intended Use

Asentinel provides global telecommunication expense management and mobility management solutions. In the performance of these services, the information we receive from our corporate clients may contain one or more of the following data elements which is considered personal information related to the employees of our corporate clients: corporate employee identification number, name, title, corporate email address, department/cost center, corporate phone numbers, and corporate address. Additionally, we receive telecommunication invoices including call detail records associated with devices, services, and networks for which Asentinel corporate clients are either primarily or secondarily liable.

This information is used for the sole purpose of matching charges and telecommunications inventory to the appropriate employee and/or department/cost center within Asentinel’s corporate client enabling the corporate client to manage the acquisition, tracking, use, and disposal of these corporate assets.

In addition, parties visiting our website (www.asentinel.com) can visit the site without providing personal information; however, computers connected to the internet contain information such as IP (Internet Protocol) Address, and domain names that identify the computer and network used to access our web site. This information is captured and stored solely for tracking and monitoring purposes.

Data Integrity

Asentinel employs reasonable and generally accepted measures to protect corporate client information from loss, misuse, unauthorized access, disclosure, alteration and destruction of information which includes compliance with confidentiality and non-disclosure provisions in agreements between Asentinel LLC and its corporate clients, partners, suppliers, and employees. Corporate clients agree to Asentinel’s capture and use of corporate employee data for their corporate use. Asentinel may disclose data in response to lawful requests by public authorities including to meet national security or law enforcement requirements.

Asentinel’s managed and hosted solutions maintain corporate client information on secure servers located in secure data centers. Unique login ids and passwords are required to access the personal information stored in databases which is only used for the intent described in this policy. Corporate client login ids and passwords are provided to corporate clients in order to allow access to the information pertaining to the specific corporate client for whom it is intended. All access to corporate client data, whether it is corporate client or internally accessed, is controlled and monitored by Asentinel’s information technology staff.

All servers are protected by one or more firewalls restricting access to the individuals for which access is specifically intended. Extensive monitoring and security tools are utilized to ensure confidentiality, integrity, and availability.

Asentinel does not currently use third-parties however Asentinel does reserve the right to use third-party contractors to supplement staff activities. Asentinel remains responsible and liable under the Privacy Shield Principles if third-party contractors process the data in a manner inconsistent with the Privacy Principles, unless Asentinel proves that it is not responsible for the event giving rise to the damage.

Enforcement

Asentinel will periodically conduct audits to ensure that corporate client data is maintained in a manner consistent with this Privacy Policy and the principles of the EU-U.S. Privacy Shield framework and U.S.-Swiss Safe Harbor Framework.

Dispute Resolution

In compliance with the Privacy Shield Principles, Asentinel commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Private Shield policy should first contact Asentinel at:

Director of Infrastructure and Security
Asentinel LLC
6410 Poplar Avenue, Suite 200
Memphis TN 38119 USA
(901) 752-6200

Individuals have the right to access their personal data. Asentinel will work with its corporate client to limit the use of the individual’s personal data.

Asentinel 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, or if we have not addressed your complaint to your satisfaction, please contact or visit www.jamsadr.com for more information or to file a complaint. The services of JAMs are provided at no cost to you. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option maybe available before a Privacy Shield Panel as indicated in the Privacy Shield Framework, Annex I. Asentinel is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.