Protecting privacy is critical to our business. ARA complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of information transferred between the European Union and Switzerland and the United States. ARA adheres to the Privacy Shield Principles as certified under the Department of Commerce. ARA’s certification can be viewed here: https://www.privacyshield.gov/.
ARA will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Privacy Principles and applicable law (including without limitation the European Union General Data Protection Regulation, or “GDPR”). ARA will respond to a complaint within forty-five (45) days of receipt. For complaints that cannot be resolved, ARA commits to cooperate with the panel established by the European Union data protection authorities (“DPAs”) or the Swiss Federal Data Protection and Information Commissioner, as applicable, and, in accordance with applicable law, comply with the valid legal advice given by the panel or Commissioner with regard to Personal Information transferred from the European Union or Switzerland. ARA commits to cooperate with European DPAs and comply with the advice given by such authorities regarding human resources data transferred from the EU in the context of the employment relationship. This independent dispute resolution process is provided at no cost to you. Under the Privacy Shield Principles, you may choose to invoke binding arbitration via ARA’s arbitration provider, the International Centre for Dispute Resolution (ICDR/AAA) to resolve any residual complaints not resolved by any other means. Access the ICDR/AAA site here: http://go.adr.org/privacyshield.html.
ARA’s commitments under this Policy are subject to the enforcement powers of the U.S. Federal Trade Commission (“FTC”).
