Introduction

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.

CenterEdge complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  CenterEdge has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

As a third-party processor, CenterEdge will not collect personal information directly from consumers in the EEA.  Any information collected via an online store operated by CenterEdge will be considered as if collected by our customer, and provided to us as a third-party processor.  It is the responsibility of CenterEdge’s customers who use our online store services to maintain their own privacy policy and ensure that it is followed.  CenterEdge will only process personal information in the manner agreed to with our customer, or at the direct instruction of our customer. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Definitions

“Personal Information” or “Information” means information that (1) is transferred from the EU 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.

Principles

Notice

CenterEdge notifies Customers about its adherence to the Privacy Shield principles through its publicly posted website privacy policy, available at http://centeredgesoftware.com/privacyshield/.

Choice

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 individuals received pursuant to the EU-US Privacy Shield, CenterEdge is potentially liable.

Security

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.

Data Integrity

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.

Access

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

Company uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. CenterEdge is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

In compliance with the EU-US Privacy Shield Principles, CenterEdge commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding this privacy policy should first contact CenterEdge at:

CenterEdge Software
Privacy Resolution Department
PO Box 1359
Roxboro, NC 27573

CenterEdge has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles 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.

US Swiss Safe Harbor

CenterEdge complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland.  CenterEdge has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, accountability, security, data integrity, access and enforcement.  If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern.  To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/

In compliance with the US-Swiss Safe Harbor Principles CenterEdge commits to resolve complaints about your privacy and our collection or use of your personal information.  Swiss citizens with inquiries or complaints regarding this privacy policy should first contact CenterEdge at:

CenterEdge Software
Privacy Resolution Department
PO Box 1359
Roxboro, NC 27573

Center Edge has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism 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 http://www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of the Privacy Shield. We will post any revised policy on this website.

Effective Date: September 9th, 2016