Privacy Policy

Overview


Perfect Sense is entrusted with the responsibility to provide Managed Services of Brightspot, our Digital Experience Platform (DXP) as outlined in each of the contracts and Service Level Agreements with Perfect Sense’s customers. Through our SLAs, legal, and regulatory requirements, Perfect Sense is obligated to exercise professional due care in the handling of privacy data. Inherent in this responsibility is an obligation to provide appropriate protection against various threats to the privacy of Perfect Sense’s customers.

The Managed Services of Perfect Sense is contracted to provide the operation of our customer’s websites in a cloud environment. Perfect Sense does not collect data; however, Perfect Sense has access to the data that our customers’ have collected. Perfect Sense is bound to the SLAs, legal and regulatory requirements to protect and not share privacy information to third-parties. Perfect Sense’s Managed Services only processes personally identifiable information in accordance with the terms of the applicable agreement between Perfect Sense and the client.

Perfect Sense manages a website for business purposes. The www.perfectsensedigital.com primary purpose is to serve as a tool for prospective clients and employees to learn more about Perfect Sense and our offerings.

EU-US Privacy Shield


Perfect Sense, Inc. participates in the EU-U.S. Privacy Shield program and complies with the EU-U.S. Privacy Shield Framework as set forth by the United States Department of Commerce regarding the collection, use, and retention of personally identifiable information transferred from the European Union.

Perfect Sense has self-certified to the Department of Commerce that it adheres to the Privacy Shield Principles. More information on the EU-U.S. Privacy Shield and the scope of Perfect Sense’s participation in the EU-U.S. Framework is available at https://privacyshield.gov/welcome

Managed Services - Collected Personal Information


Managed Services performed on behalf of our customers may collect Personal Information, which is information that identifies an individual or relates to an identifiable individual. Personal Information may include, but is not limited to:

● Your name and physical address, email addresses, and telephone numbers
● Behavioral or demographic attributes, when tied to personal identifiers
● Unique IDs such as a cookie placed on your computer, mobile or device IDs
● Internet Protocol address ("IP address") and information derived from your IP address such as your geographic location
● Information about your devices such as information contained in HTTP Headers or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings and information about or from the presence or use of "apps" on your mobile devices, screen resolution, and your preferred language
● Behavioral data about your usage of our client’s website such as webpages clicked, content areas visited, date and time of activities
● The web search you used to locate and navigate to our client’s website

Perfect Sense Website – Collected Personal Information

● Job Application- Your name, physical address, email address, and telephone number
● Record of Correspondence (If you contact us)
● IP address, operating system and browser type (We do not use cookies)


How We Use and Share Information


Managed Services
Perfect Sense does not use or share data unless mandated by contract or via legal request. Privacy data, if collected, is not utilized or shared in any way by Perfect Sense. Perfect Sense may have access to privacy data; however, that access only pertains to a limited number of employees that are maintaining the website in a cloud environment from a security and availability perspective.

Perfect Sense Website
Perfect Sense does not sell or share personal data to third-parties. Data is used for employment purposes (resume/job application) or direct correspondence for business inquiries.

Accountability for Onward Transfer


Perfect Sense is accountable for personally identifiable information that we receive and subsequently transfer to third parties. If third parties that process personally identifiable information on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.

Contact information and customer’s personally identifiable information is accessible only by those Perfect Sense employees and consultants who have a reasonable need to access such information in order for us to fulfill contractual, legal and professional obligations. All of our employees and consultants have entered into confidentiality agreements, and/or have been subjected to thorough criminal background checks requiring that they maintain the confidentiality of Customer personally identifiable information.

In the event Perfect Sense discloses personally identifiable information covered by this Policy to a non-agent third party, it will do so consistent with any notice provided to Data Subjects and any choice they have exercised regarding such disclosure. Perfect Sense will only disclose personally identifiable information to third-party agents that have given us contractual assurances that they will provide at least the same level of privacy protection as is required by this Privacy Policy and the Principles and that they will process personally identifiable information for limited and specific purposes consistent with any consent provided by the individual. If Perfect Sense has knowledge that a third party to which it has disclosed personally identifiable information covered by this Privacy Policy is processing such personally identifiable information in a way that is contrary to this Privacy Policy and/or the Principles, Perfect Sense will take reasonable steps to prevent or stop such processing. In such case, the third-party is liable for damages unless it is proven that Perfect Sense is responsible for the event giving rise to the violation.

Perfect Sense may use from time to time a limited number of third-party service providers, contractors, and other businesses to assist us in providing our solutions to our customers or in meeting internal business operation needs. These third-parties may access, process, or store personally identifiable information in the course of performing their duties to Perfect Sense. Perfect Sense maintains contracts with these providers restricting their access, use and disclosure of personally identifiable information in compliance with our obligations under the Privacy Shield Principles.

Updating, Retention, and Deletion of Personally Identifiable Information


Managed Services
Perfect Sense does not retain any privacy data. Perfect sense will ensure deletion and sanitization of data per Service Level Agreements and regulatory requirements on behalf of our customers. All questions for updating your personal data must be directed to the website owner (our customer).

Perfect Sense Website
You are entitled to know whether we hold personal data about you and if we do, to have access to that personal data and require it to be amended, corrected, or deleted if it is inaccurate. You can accomplish this through our contact information below.

Enforcement and Liability


Perfect Sense is subject to the jurisdiction and enforcement and investigative authority of the United States Federal Trade Commission.

Security


Perfect Sense employs procedural and technological measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Perfect Sense may use encryption, secure socket layer, firewall, secure shell, event management tools, and other logical and physical security measures.

Dispute Resolution


Perfect Sense assures compliance with EU-U.S. Privacy Shield by fully investigating and attempting to resolve any complaint or dispute regarding the use and disclosure of personally identifiable information in violation of this Privacy Policy.

Any questions or concerns regarding the use or disclosure of personally identifiable information should first be directed to the owner of the website in question (our customer); or if the question or concern is from our customer, then to Perfect Sense at the address given below.

Perfect Sense will respond to any inquiries or complaints within forty-five (45) days. In the event that Perfect Sense fails to respond or it response is insufficient or does not address the concern, Perfect Sense has registered with JAMS to serve as the independent recourse mechanism for dispute resolution at no cost to the complaining party. To contact JAMS and to learn more about the JAM’s dispute resolution services, including instructions for submitting a complaint, please visit: https://jamsadr.com/eu-us-privacy-shield.

Contact Us


If you have any questions or complaints regarding the Privacy Policy please contact us by mail:

Perfect Sense, Inc.
12120 Sunset Hills Road, 6th Floor
Reston, VA 20190
Attention: Chief Privacy Officer

 

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