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IIJ America, Inc. Safe Harbor Privacy Policy

IIJ America, Inc. Safe Harbor Privacy Policy

IIJ America, Inc., ("IIJ America"), the US subsidiary of Internet Initiative of Japan Inc., is a provider of Internet backbone and cloud services to governments, businesses and other entities throughout the world.  Under its IIJ GIO US Service brand, IIJ America connects high-end servers in the United States to the IIJ Group’s Internet backbone network.  This Safe Harbor Privacy Policy covers IIJ America’s privacy practices pertaining to the transfer of Personal Information from EU Member States and Switzerland to the United States in connection with its cloud services.

US-EU Safe Harbor Framework and US-Swiss Safe Harbor Framework

Consistent with its commitment to protect personal privacy, IIJ America adheres to the US-EU Safe Harbor Framework and the US-Swiss Safe Harbor Framework, and the Safe Harbor Privacy Principles, as applicable, regarding the transfer of Personal Information from EU Member States and Switzerland to the United States.

Definitions

The following definitions apply throughout this Safe Harbor Privacy Policy:

Personal Information.  “Personal Information” means any information or set of information that is transferred from the European Union and Switzerland to the United States, is recorded in any form, pertains to or is about any individual, or can be linked to or used to identify that individual.

Sensitive Personal Information.“Sensitive Personal Information”is Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal proceedings or convictions, or that concerns health or sexual activity.

Status as a Data Processor

In the provisioning of cloud computing services, IIJ America acts solely as a “Data Processor” for the transfer of its customer services data from EU Member States and Switzerland to the United States for processing.  A Data Processor is an organization that processes Personal Information and/or Sensitive Information purely on behalf of and pursuant to the instructions of a Data Controller.  IIJ America provides these services under contract to its clients in the European Union and Switzerland and, accordingly, IIJ America holds, processes and/or transfers such customer services data at the direction of its client, which acts as a Data Controller.  Accordingly, IIJ America’s customers, as Data Controllers, decide what data to hold about what categories of Personal Information and about what categories of individuals.   IIJ America does not control this customer services data and any access to or use of such data is incidental to IIJ America completing its contractual obligations to its clients.  (See US-EU Safe Harbor Framework Guide to Self-Certification, FAQ X)

Moreover, as a Data Processor, IIJ America has no relation with the data subjects.  Any obligation to determine whether to provide notice to data subjects regarding what Personal Information is collected about them and how it is used, or to obtain their consent, rests with IIJ America’s clients as Data Controllers.  IIJ America will process Personal Information only as directed by its clients.

IIJ America notes that the Safe Harbor Privacy Principle of onward transfer  applies to Data Processors; however, IIJ America  does not use third-party subcontractors when processing Personal Information at the direction of its clients.  In addition, IIJ America will, whenever necessary, assist its clients in dealing with any access requests from individual data subjects, and will pass any requests for access received to them.  Incident to its provision of cloud services, IIJ America collects limited information regarding its clients: a contact name, business phone number and business email address.  This information is collected for internal administrative purposes only and is not disclosed to any third parties.

As a Data Processor, IIJ America takes the security of Personal Information very seriously.  Accordingly, it has implemented appropriate technical and organizational measures against unauthorized or unlawful processing of Personal Information and against accidental loss of, or damage to, Personal Information.

Inquiries and Dispute Resolution

Any inquiries regarding this Safe Harbor Privacy Policy and Personal Information collected by IIJ America should be directed to:

Corey Watanabe
Chief Financial Officer
55 E. 59th Street, #18
New York, NY  10022  USA
(212) 440-8080
www.iijamerica.com/english/
safeharborprivacy@iij-america.com

JAMS International provides IIJ America's third-party, independent dispute mechanism as required under the US-EU Safe Harbor Framework and US-Swiss Safe Harbor Framework. If you have a complaint about IIJ America's Safe Harbor compliance that cannot be resolved directly with IIJ America, contact JAMS International at www.jamsinternational.com/rules-procedures/safeharbor/file-safe-harbor-claim.

IIJ America’s Safe Harbor self-certification statement may be accessed on the Safe Harbor program website: https://safeharbor.export.gov/list.aspx .

Changes

This Safe Harbor Privacy Policy is subject to change from time to time.  IIJ America will endeavor to post a notice of any changes to this Privacy Policy for a period of thirty (30) days following any such modifications. Therefore, you are advised to review this Privacy Policy occasionally, or at least every thirty (30) days.  The Effective Date of this Safe Harbor Privacy Policy will be updated when any such changes are made.
If any term or provision of this Safe Harbor Privacy Policy shall be found to be invalid, illegal or otherwise unenforceable, such finding shall not affect the other terms or provisions of this Safe Harbor Privacy Policy, or the whole of this Safe Harbor Privacy Policy, but such term or provision shall be deemed modified to the extent necessary to render such term or provision enforceable, and the rights and obligations of you and IIJ America shall be construed and enforced accordingly, preserving to the fullest permissible extent the intent and agreements set forth in this Safe Harbor Privacy Policy.

Contact Information

Questions or comments regarding this Safe Harbor Privacy Policy may be submitted to IIJ America at safeharborprivacy@iij-america.com.

Effective Date:  May 1, 2014

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