Organization Information:

Emptoris, Inc.
200 Wheeler Road
Burlington, Massachusetts 01803
Phone: 781.852.2800
Fax: 781.993.9213
Contact Information:

Contact Office: Data Privacy
Contact Name: Terrence Curley, VP Operations & Data Privacy Officer
Phone: 781.852.2865 Fax: 781-993.9213 Email:

Corporate Officer Information:

Corporate Officer: Terrence Curley, VP Operations & Data Privacy Officer
Phone: 781.852.2865 Fax: 781.993.9213 Email:

Safe Harbor Information:

Signed up to safe harbor 09/30/2008 01:02:31 PM
Next certification 09/30/2009
EU/EEA Countries From Which Personal Information Is Received: France, Germany, Hungary, Ireland, Italy, Netherlands, Poland, Spain, Sweden, United Kingdom
Industry Sector: Computer Software - (CSF) Computer Services - (CSV)
Personal Information Received From the EU: Emptoris role in data protection and privacyis generally limited by its position as a spend analysis software solution provider. Emptoris currently receives data from entities located globally for the purpose of helpingclients identify where and how they are spending their resources, particularly cash resources. Emptoris receives spend data from clients wishing to have their spend data analyzed. The data comes in many forms. Emptoris collects, standardizes and analyzes the spend data (processing purposes only) then makes reports of the analysis available back to the clients. Any personal data provided to Emptoris is incidental to the spend data. Emptoris does not use the personal data for any purpose nor does it transfer the information to anyone.
As set forth in FAQ 10 of the Safe Harbor Framework, data controllers in the European Union are always required to enter into a contract when a transfer for mere processing is made, whether the processing operation is carried out inside or outside the EU. The purpose of the contract is to protect the interests of the data controller, i.e. the person or body who determines the purposes and means of processing, who retains full responsibility for the data
the individual(s) concerned. The contract thus specifies the processing to be carried out and any measures necessary to ensure that the data is kept secure. Emptoris is currently subject to and will enter into a written contract with any EU Member, prior to processing any such electronic data. The contract will contain terms and provisions regarding each respective party’s rights and obligations as it relates to the processing of data for spend analysis purposes. This will ensure that the EU data controller will be in compliance with the Member State Data Protection law. Any data processed by Emptoris will not be disclosed to third parties, except where permitted or required by the contract between the EU Member and Emptoris. Any information, which an Emptoris customer (acting as the EU controller) identifies as sensitive information will be treated accordingly.
Emptoris has in place and will provide as such in a Master Agreement with any EU Member that Emptoris has adequate data security measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration or destruction.
Privacy Policy Effective: March 30, 2008
Regulated by: Federal Trade Commission
Privacy Programs: None
Verification: In-house
Dispute Resolution: Emptoris is committed to cooperate with the EU Data Protection Authorities located in the European Community or their authorized representatives to resolve disputes pursuant to the Safe Harbor principles.
Personal Data Covered: on-line
Human Resource Data Covered: No

Do you agree to cooperate and comply with the European Data Protection Authorities? Yes

Certification Status: Current
Compliance Status:

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