Pathfinder Software, LLC D/B/A CenterEdge Software (“CenterEdge”) is a leader in the entertainment software industry. In this capacity, we operate as a processor of personal information for our customers in the European Economic Area (“EEA”) and Switzerland. The EEA includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein, and Norway.
“Personal Information” or “Information” means information that (1) is transferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.
As a general matter, CenterEdge collects the following types of Personal Information from its Customers: contact information (including, a contact person’s name, email address, mailing address, telephone number); driver’s license information; date of birth; gender; and payment information (inclusive of credit card information; this data is handled compliant to PCI guidelines). Customers have the option to log into their accounts online and update their Personal Information as necessary.
CenterEdge will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, CenterEdge will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual the same as the individual would treat and identify it as Sensitive Personal Information.
Accountability for Onward Transfers
Prior to disclosing Personal Information to a third party, CenterEdge shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection. The only third party engaged via CenterEdge is Amazon Web Services for the sole purpose of data storage. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US or Swiss-US Privacy Shield, CenterEdge is potentially liable.
CenterEdge shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. CenterEdge has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Company cannot guarantee the security of Information on or transmitted via the Internet.
CenterEdge shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, CenterEdge shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.
CenterEdge acknowledges an individual’s right to access their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
Recourse, Enforcement, and Liability
Privacy Resolution Department
PO Box 1359
Roxboro, NC 27573
CenterEdge has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
EU-US Effective Date: September 9th, 2016
Swiss-US Effective Date: April 12th, 2017