Privacy Policy

Background

IQNavigator provides services procurement and payment automation solutions for Global 2000 enterprises. As part of its process management services, IQNavigator obtains and processes Personal Data on behalf of customers and their services suppliers. In addition, IQNavigator obtains Personal Data of website visitors who request to receive the IQUpdate quarterly e-newsletter. This Privacy Policy describes IQNavigator’s commitment to privacy and the procedures and policies to protect all the Personal Data in IQNavigator’s possession.

This Privacy Policy and the embodied procedures and policies adhere to the Safe Harbor personal data privacy principles developed by the U.S. Department of Commerce and European Commission for the protection of Personal Data for citizens of the European Union.

This Privacy Policy was last changed on March 30, 2004, and is effective as of April 5, 2004.

Definitions

Personal Data refers to any information that is identifiable to specific individuals or by which specific individuals can be identified, such as name, identification numbers, email address, mailing address, phone numbers, or other personal characteristics or attributes. Personal Data does not include information that is previously publicly available or is anonymous statistical information that is not identifiable to a specific individual.

Data Subjects refers to the individuals to whom the Personal Data refers.

Data Controller refers to the owner of the data, which in most cases is the customer or their services supplier. When the Data Controller is an IQNavigator customer or their supplier, IQNavigator performs the role of Data Processor and is obligated to uphold the customer’s or supplier’s information confidentiality and privacy policies.

Customer Confidential refers to non-public information that is proprietary to our customers or their services suppliers.

Privacy Principles

IQNavigator is committed to individual privacy and recognizes its responsibility for protecting the Personal Data in its possession and care. The IQNavigator Privacy Policy is embodied in the following principles:

Notice: Data Subjects will be notified at the time of data collection regarding what Personal Data is collected, how it will be used, and to whom it will be disclosed, either directly by IQNavigator or by the Data Controller, as appropriate. This Privacy Policy will be published prominently on IQNavigator’s website as well as via communications with Data Subjects, such as upon login to the IQNavigator software applications. This policy may change from time to time, in which case appropriate notifications will be placed in the IQNavigator software applications.

Access: Data Subjects will be granted access to the Personal Data related to them, and will be able to submit corrections to the information where it is believed to be inaccurate (see “Inquiries” below). Corrections will be subject to verification and acceptance by the Data Controller.

Data integrity: IQNavigator collects, retains and uses only relevant Personal Data necessary for conducting business. IQNavigator will take steps to ensure that the Personal Data is accurate and current.

Onward Transfer and Choice: We will not transfer Personal Data to third parties, other than the Data Controller and third parties who participate with us or our customers and their suppliers in performing the agreed-upon process management services. All such parties agree to maintain appropriate procedures to safeguard the Personal Data and use it only for the purposes described in the collection notice and as the Data Controller directs.

Security: IQNavigator will treat all Personal Data as confidential to the Data Subject and to the Data Controller, and will maintain internal procedures and security safeguards designed to prevent inappropriate disclosure, misuse, or alteration of Personal Data. IQNavigator personnel are responsible for protecting Personal Data and other Customer Confidential information, are trained in the applicable policies, and are expected to adhere to the procedures and intent of this Privacy Policy.

Enforcement: Data Subjects who believe that their Personal Data was not handled in accordance with this Privacy Policy should contact IQNavigator’s Privacy Officer (see “Inquiries” below), who will conduct an investigation and report their findings to the Data Subject. European Union (EU) residents may also make use of the appropriate Data Protection Authorities; IQNavigator will cooperate with EU Data Protection Authorities to investigate and resolve complaints, including complying with any resulting advice given by the Data Protection Authorities.

Policy Practices

Information Collected

IQNavigator receives and stores nonpublic Personal Data and other Customer Confidential information from several sources in the normal course of business, including:

• Identification and contact information from customers, their services suppliers, and the Data Subjects themselves.
• Business process information (such as regarding services procurement and payment processes) through the usage of the IQNavigator applications and communications among customer users and their services suppliers, the Data Subjects, IQNavigator users, and third-party users.
• Transaction and information system usage information from IQNavigator applications, IQNavigator websites, other contacts with IQNavigator, and third parties.

Why This Information Is Collected

IQNavigator uses this nonpublic Personal Data and other Customer Confidential information for the purposes of:

• Identifying the Data Subjects and associating their various authorized role(s) and preferences
• Contacting and notifying Data Subjects of appropriate process events and data changes
• Efficiently and accurately performing the process management services, including tasks as directed or authorized by the Data Controller.
• Improve existing services and design new services

Consequently, the Personal Data collected is generally contact information, identification information, and process-related transaction information.

How This Information Is Used

IQNavigator uses Personal Data only for the purposes for which it was collected as described above.

In the normal course of business, Personal Data and Customer Confidential information is processed by IQNavigator and via third parties who are contracted to uphold this Privacy Policy and any additional customer obligations. Personal Data may also be transferred to the Data Controller and their authorized agents in the course of performing the process management services.

In addition, IQNavigator will perform legitimate and relevant tasks as directed or authorized by the Data Controller.

Information Security

Personal Data in IQNavigator’s possession is protected by its Information Systems Security Policy, which is designed to prevent unauthorized disclosure, misuse, or alteration of Personal Data. The Information Systems Security Policy includes confidentiality procedures applicable to all IQNavigator personnel, security requirements for physical and electronic security, and compliance policies and procedures for information handling. All IQNavigator personnel are required to acknowledge understanding of the Information Systems Security Policy, and adherence is enforced.

Inquiries

To inquire about any aspect of this Privacy Policy, Personal Data held, or uses of the Personal Data, please contact the IQNavigator Privacy Officer via email at iqprivacy@iqnavigator.com, via telephone at +1-303-563-1500, or via mail to IQNavigator at 6465 Greenwood Plaza Boulevard, Suite 800, Centennial Colorado 80111 USA.

For inquiries from Data Subjects about their Personal Data, IQNavigator will forward the inquiries to the appropriate Data Controller (the customer or supplier who owns the data) and assist with resolving the inquiry, including providing access to the Personal Data and correcting any errors in cooperation with the Data Controller.

IQNavigator has certified its compliance with the Safe Harbor requirements and has registered with the U.S. Department of Commerce’s Safe Harbor website at http://www.export.gov/safeharbor.