International Data Transfers

ETS Labs collects, uses, and discloses personal information in a manner consistent with the laws of the countries in which it does business. This policy explains the safeguards ETS Labs applies when personal data is transferred from the European Economic Area (EEA), the United Kingdom, and Switzerland to the United States.

Scope

How we transfer data internationally

ETS Labs relies on the following lawful transfer mechanisms, used individually or in combination depending on the data and the parties involved:

• Standard Contractual Clauses (SCCs). ETS Labs uses the European Commission's Standard Contractual Clauses, and the UK International Data Transfer Addendum where applicable, as the primary contractual safeguard.
• EU-US Data Privacy Framework (DPF). Where ETS Labs participates in the EU-US Data Privacy Framework, transfers may rely on that framework and the adequacy decision adopted by the European Commission in July 2023.
• UK Extension to the EU-US DPF. For transfers originating in the United Kingdom, ETS Labs relies on the UK Extension to the EU-US Data Privacy Framework where applicable.
• Swiss-US Data Privacy Framework. For transfers originating in Switzerland, ETS Labs relies on the Swiss-US Data Privacy Framework where applicable.
• Other safeguards. Where appropriate, ETS Labs may also rely on binding corporate rules, a data subject's explicit consent, or another safeguard recognized under applicable data protection law.

ETS Labs maintains Standard Contractual Clauses as a backup safeguard for transfers that rely on the Data Privacy Framework, so that a valid transfer mechanism remains in place if the framework's status changes.

The principles we follow

Whichever mechanism applies, ETS Labs commits to the following data protection principles:

Notice

Where ETS Labs collects personal information directly from individuals, it informs them about the purposes for which it collects and uses that information, the types of third parties to which it may be disclosed, and the choices and means ETS Labs offers for limiting use and disclosure.

Choice

ETS Labs offers individuals the opportunity to choose whether their personal information is disclosed to a third party acting outside our instructions, or used for a purpose materially different from the purpose for which it was originally collected.

Accountability for onward transfer

When ETS Labs transfers personal data to third parties acting as processors on our behalf, it does so under contract, requires those parties to provide at least the same level of protection set out in this policy, and remains accountable for processing carried out on its behalf.

Security

ETS Labs takes reasonable and appropriate precautions, including physical, electronic, and administrative measures, to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

Data integrity and purpose limitation

ETS Labs uses personal information only in ways compatible with the purposes for which it was collected or subsequently authorized.

Access

Upon request, ETS Labs grants individuals reasonable access to the personal information it holds about them, and reasonable means to correct, amend, or delete information shown to be inaccurate or incomplete.

Recourse, enforcement, and liability

ETS Labs uses internal mechanisms to verify its adherence to this policy and provides recourse for individuals affected by non-compliance.

Sensitive personal information

Sensitive personal information means information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health, sex life, or other categories treated as sensitive under applicable law. ETS Labs treats as sensitive any information that a customer or third party identifies and provides to us as sensitive. ETS Labs obtains affirmative, explicit consent before disclosing sensitive information to a third party outside our instructions or using it for a materially different purpose.

Onward transfers to processors

ETS Labs obtains assurances from its processors and subprocessors that they will safeguard personal information consistently with this policy.

Access and correction

Individuals may request access to the personal information ETS Labs holds about them. Requests can be made by email to safeharbor@qeval.ai.

Security

ETS Labs maintains an information security program with physical, electronic, and administrative safeguards designed to protect personal information in its possession.

Recourse, enforcement, and dispute resolution

ETS Labs conducts internal reviews of its relevant privacy practices to verify adherence to this policy. Any employee found to have intentionally violated this policy is subject to disciplinary action up to and including termination of employment.

Questions or concerns regarding the use or disclosure of personal information should be directed to ETS Labs InfoSec at the address below. ETS Labs will investigate and attempt to resolve complaints regarding the use and disclosure of personal information in accordance with the principles in this policy. If a complaint cannot be resolved directly, ETS Labs will cooperate with the relevant data protection authorities and any independent recourse mechanism that applies to the transfer in question.

Limitations on application of principles

Adherence to these principles may be limited to the extent required or permitted by law or legal process, such as responding to a lawful request from public authorities, including to meet national security or law enforcement requirements, or to the extent expressly permitted by an applicable law, rule, or regulation.

Changes to this policy

ETS Labs may amend this policy from time to time, consistent with the requirements of applicable data protection law. When this policy is changed in a material way, ETS Labs will post a notice on this page.

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