Defined Benefit Services, LLC (Defined Benefit Services) is committed to integrity and fairness in our business practices with our clients and their employees. This commitment extends to personal information which we may receive during our operations.

We strive to protect the personal information under our control and take certain precautions to help maintain the security and accuracy of that data. If you have questions or concerns regarding this statement, you should contact Defined Benefit Services using the contact information included at the end of this policy.

Defined Benefit Services collects information in the course of providing services to its clients from internal and external information systems, as well as from the usage of online applications. This information may include, but is not limited to your name, address, email address, employment and demographic data. This information is stored solely for use in providing applications for our clients such as delivering fulfillment services to their employees, online services for them, and related reporting, analysis, and program design services. Defined Benefit Services will not sell, rent or lease your personal information.

Defined Benefit Services complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the UK, and/or Switzerland to the United States. Defined Benefit Services has certified to the Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Defined Benefit Services has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To view the Privacy Policies of Defined Benefit Services for Personal Data, please click here. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit http://www.dataprivacyframework.gov

We do not generally transfer personal information to third parties. As such, liabilty for onward transfers to third parties will generally not apply. However, for any personal information received under the Data Privacy Framework by Defined Benefit Services and subsequently transferred to a third party acting as an agent on its behalf, Defined Benefit Services shall retain responsibility for the processing of such personal information and remain liable for damages caused by such agent in processing such personal information in a manner inconsistent with the principles of the Data Privacy Framework, unless it is proven that it is not responsible for the event giving rise to the damage. Please note that Defined Benefit Services may be required to disclose personal information in response to lawful requests by public authorities, including obligations to meet national security or law enforcement requirements.

Defined Benefit Services works closely with its clients to provide accurate data. Individuals may have certain rights of access to personal information, to opt out, and to have such data deleted or corrected where incorrect. For more information, please visit: https://www.dataprivacyframework.gov/framework-article/6–ACCESS and/or https://www.dataprivacyframework.gov/framework-article/8–Access. If you need to reach the Defined Benefit Services Privacy Officer, please use address shown below or email privacy@definedbenefitservices.com.

For more information, please visit: https://www.dataprivacyframework.gov/framework-article/5–DATA-INTEGRITY-AND-PURPOSE-LIMITATION.

If personal data covered by this Privacy Policy is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party in a manner not specified in this Policy, either your Human Resources (HR) Department or Defined Benefit Services will obtain your affirmative and explicit consent (opt-in). Note: For more information, please visit: https://www.dataprivacyframework.gov/framework-article/2–CHOICE and/or https://www.dataprivacyframework.gov/framework-article/12–Choice--Timing-of-Opt-Out

Defined Benefit Services, LLC is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Defined Benefit Services commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Defined Benefit Services at:

Chief Privacy Officer
Defined Benefit Services, LLC
601 Carlson Pkwy Ste 1050
Minnetonka, MN 55305
U.S.A.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Defined Benefit Services commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF in the context of the employment relationship.

Under certain conditions, it may be possible to invoke binding arbitration for matters not resolved by any of the other Data Privacy Framework mechanisms, as described in more detail in Annex I available here: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf. Defined Benefit Services has committed to refer unresolved Data Privacy Framework complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from Defined Benefit Services, or if your complaint has not been addressed to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

We value your opinions. If you have comments or questions about our privacy policy, you may also contact us at the following address:

Chief Privacy Officer
Defined Benefit Services, LLC
601 Carlson Pkwy Ste 1050
Minnetonka, MN 55305
U.S.A.