Last Updated: August 02, 2017

Privacy Policy

This Privacy Policy explains the information practices and policies of Continuum Managed Services Holdco (“Continuum”). It describes how we collect, use, and disclose information as users interact with the managed information technology services that we provide to our business partners and their clients (collectively, “clients”) and how we collect and use information from visitors to any websites owned by Continuum (“Continuum Websites”).  For the purposes of this Privacy Policy, the terms “we”, “us” and “our” refer to Continuum and “you” refers to you, as a visitor to any of the Continuum Websites and anyone else who provides their personal information directly to us.

This Privacy Policy does not reflect the privacy policies or practices of Continuum clients or any other third party.  Continuum is not responsible for the privacy policies or practices of any client or other third party.

I. Privacy Shield Policy

Continuum and its subsidiary R1Soft have adopted this Privacy Shield Policy as part of their overall Privacy Policy to establish and maintain an adequate level of privacy protection to Personal Information that Continuum obtains from Customers located in the European Union.

Continuum and R1Soft comply with the US-EU Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Individual Customers in the European Union member countries. Continuum has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

II. About Continuum

We provide managed information technology (“IT”) services and solutions to our clients, including remote monitoring and management, network operations technical support, white label technology help desk services, and backup and disaster recovery management, among others (collectively, the “Services”). 

Any Personal Information (defined below) we collect, use, and disclose through our Services is only processed on our clients’ behalf and as authorized and directed by those clients.  It is the Continuum client’s responsibility to ensure that the data it collects or directs us to collect through Continuum’s Services can be legally collected. It is also the client’s responsibility to provide its employees and customers the appropriate level of notification that information, potentially including Personal Information, will be collected and maintained.

II. How We Collect, Use, and Share Information

We primarily collect Personal Information that is necessary for us to provide our Services to our clients. We will also collect Personal Information in the ordinary course of running our business, including through the receipt of communications such as emails, website enquiries and telephone calls.

When we say, “Personal Information,” we mean individually identifiable information that alone or when in combination with other information may be used to readily identify, contact, or locate a specific person, such as a name, address, phone number, username, email address, and password. Unless it is defined otherwise under local law in a specific jurisdiction, we do not consider Personal Information to include information that has been anonymized or publicly available information that has not been combined with non-public Personal Information.

Information Collected through Our Services and Continuum Websites

We usually collect information, including Personal Information, in the following ways:

Personal Information. We may collect Personal Information about users of a client’s IT systems in order to provide our Services and as authorized by that client. We may collect such Personal Information directly or indirectly, such as through a client or another service provider.  We may also collect Personal Information from you as a user of the Continuum Websites or by other direct communication from you. For example, when you register for our Services or request additional information or contact from Continuum, you may be asked to provide certain Personal Information, which may include a name, company name, address, and email address. In addition, if you choose to communicate with us via a web form, email or by telephone, we may retain the content of your communication together with your email address or phone number and our responses. If you should enter into a client relationship with Continuum, you may obtain additional rights or agree to additional obligations associated with the collection, use, and disclosure of information.

Device-related Information. We may also collect device related information from the user’s device, including information such as an IP address, the date and time of use of our Services, the date and time of an event on the client’s IT systems, system logs, and technical attributes about the device or a web browser.

Commercially Available Information. Continuum also collects information from commercially available sources. Such information may include names, addresses, email addresses, and demographic data. The information Continuum collects from these commercial sources may be combined and cross-referenced with information collected through the Continuum Services.

Continuum Websites. You can visit the Continuum Websites without revealing any Personal Information however it may prevent you from engaging in certain aspects of the Continuum Websites or other Services.

Cookies or Similar Technologies.Continuum Websites use cookies. A "cookie" is a small text file that contains a string of alphanumeric characters. There are two types of cookies that may be used at Continuum's Websites: persistent cookies or session cookies. A persistent cookie gets entered by your Web browser into the "Cookies" folder on your computer and remains there after you close your Web browser. Persistent cookies may be used by your browser on subsequent visits to the site; however, session cookies are held temporarily in your computer's memory and disappear after you close your browser or shut off your computer.

If you have arrived at any Continuum Website by clicking on a banner ad for one of Continuum's products or services, a session cookie may be used. This cookie contains an identification number for the advertisement that you clicked on, and it helps Continuum determine which of its ads attracts the most visitors. If you choose to request further information from us about Continuum's products and services, the personal information that you provide in that request will be linked to the information in the session cookie.

In order to better understand how our sites are used, Continuum Websites may also use persistent cookies along with other information collected in our servers' files (e.g., IP Address, referring URLs, etc.). Such information is not combined with information from any other cookie. Cookies may be delivered in a first-party or third-party context.

If you do not want Continuum Websites to collect information through the use of cookies, you can set your web browser to reject cookies from Continuum websites.  Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences.  If you reject or block cookies, Continuum Websites may not function as intended.

How We Use Information Collected through Our Services and Continuum Websites

To Serve Our Clients. We use the information we collect, including Personal Information, to provide our Services to the clients on whose behalf we are acting.  For example, in order to provide technical support, we may contact a user of a Continuum client’s IT system using any contact information provided to us.

To Serve You. We use the information we collect, including Personal Information, to respond to any request or query directed to us, to provide you with our products and Services and to manage our relationship with you. For example, we may respond to a job application, address any enquiries or complaints you may have, endeavor to improve the Services we provide, or provide you with information about other products and services we offer that we think you may be interested in.

For Direct Marketing. If we intend to use your Personal Information for direct marketing, such as by adding you to a marketing database, we will notify you and will provide you with an opportunity to opt out in accordance with section III.

For Internal and Service-Related Purposes.We may use any information we collect through the Services for internal and service-related purposes, including providing it to third parties as necessary to allow us to facilitate provision of the Continuum Services.

Anonymized and Aggregate Data. We anonymize and aggregate data collected through our Services and may use it for any purpose.

How We May Disclose Information Collected through Our Services and Continuum Websites

We may share any information we collect, including Personal Information, with the client on whose behalf we are acting. We do not rent, sell, or share Personal Information collected through our Services or Continuum Websites with other people or nonaffiliated companies for their direct marketing purposes. We may otherwise share information we collect as follows:

Anonymized and Aggregate Data. We may share anonymous or aggregated data with our affiliates, agents, and current and prospective business partners for any purpose, subject to our agreements with our clients.

With Our Third-Party Vendors and Service Providers. As appropriate, we may share any information, including Personal Information, we receive with vendors and service providers retained in connection with the provision of the Continuum Services. These third parties have access to Personal Information to the extent necessary to permit them to do their jobs, however, they are bound by confidentiality agreements before any information is provided to them, and they are restricted from using the information for other purposes. For Personal Information transferred to us from European Union member countries under the EU-US Privacy Shield, we will remain liable under the Privacy Shield Principles if our agents or service providers process such Personal Information in a manner inconsistent with the Privacy Shield Principles, unless we will prove that we are not responsible.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose information , including Personal Information, if we believe doing so is required or appropriate: to comply with national security or law enforcement requests and legal process, such as a court order or subpoena; to respond to your requests; to prevent or address fraud, security, or technical issues; or to protect our property or other legal rights or the rights or property of others.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, information collected through the Services or Continuum Websites (or both) may be sold or transferred as part of such a transaction, as permitted by law and/or contract. We cannot control how any other party to the transaction or any future entity created by the transaction may use or disclose such information however we will only disclose the information if the party acquiring the information agrees to be bound by the terms of this Privacy Policy.

Other than as stated in this Privacy Policy, we will not release Personal Information to unaffiliated third parties, and we will not cross-reference Personal Information collected through one client’s use of our Services with that of any other client or entity.

 

From time to time, we may also ask our partners or clients to voluntarily provide us with the email addresses of friends or colleagues, so they too can benefit from the various products and services offered by Continuum and Continuum's trusted affiliates.

III. Access, Integrity, Retention, and Choices

Access & Correction

When providing Services, we collect information at the direction of our clients and generally do not have a direct relationship with the individual users of their IT systems whose information we may process. To request access to, correction, amendment, or deletion of Personal Information, a user of a Continuum client’s IT system should direct their query to that company.

If you wish to request access to, correction, or deletion of Personal Information you have submitted through the Continuum Websites, you can log into your account or contact Continuum at privacy@continuum.net.

Data Integrity

Continuum will use Personal Information only in ways compatible with the purpose for which it was collected or authorized by our clients, or as requested in connection with Continuum Website user requests or other direct requests.

Information Retention

We keep information we need to provide our Services only so long as we have a valid business purpose, in accordance with applicable law and our client agreements.  We may retain aggregate or anonymous information indefinitely.

User Choices

By using the Continuum Websites or the Services, or otherwise providing us with information, you are giving your express consent to the collection, use, retention, transfer and disclosure, including cross-border disclosure to recipients in a foreign country, including but not limited to the European Union, United States, Australia, and India of your information as described in this Privacy Policy. You have the right to object to the disclosure of your information to third parties as described in this Privacy Policy, except for disclosures made to our third-party vendors and service providers, as well as to the use of your information for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized by you. If you wish to opt out and withdraw your consent, you may do so at any time by writing to privacy@continuum.net. If you opt out and withdraw your consent you will no longer be able to use the Continuum Websites or the Services or receive updates or other communications, and we will not have any means by which to respond to your inquiries.

We include an “unsubscribe” hyperlink in Continuum marketing emails for those users who wish to stop receiving email communication from Continuum.  The hyperlink will connect to one of our websites, which will confirm the email address that has been automatically unsubscribed and will no longer receive emails from Continuum. 

IV. Security

We take steps to ensure that information is treated securely and in accordance with this Privacy Policy. Unfortunately, neither the Internet nor any form of electronic storage can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information provided to us.  To the extent permitted by law, we do not accept liability for any unintentional disclosure.

Continuum has adopted physical, technological, and administrative procedures to safeguard and secure the information we process. We enforce least privilege access policies for our employees who have access to Personal Information.  Our employees are trained at least annually on IT security and privacy protection. Continuum’s Chief Information Security Officer is responsible for maintenance and operation of all information technology risk management programs, security controls and activities world-wide.

By providing Personal Information to us or using the Continuum Websites, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services and the Continuum Websites.

V. Non-EU International Use

Continuum is headquartered in the United States of America, but we are a growing corporation with operations in multiple countries.  We have developed data practices intended to assure information is appropriately protected.  Personal Information may be accessed by us or transferred to us in the United States or to our affiliates, partners, merchants, or service providers elsewhere in the world, including  the United Stated, European Union, Australia, and India. 

If you are visiting the Continuum Websites from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally.  By providing your information, you consent to any transfer and processing in accordance with this Privacy Policy.

VI. For users in the European Union (EU) and the European Economic Area (EEA).

We comply with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the processing of personal information from European Union member countries. We have certified that we adhere 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/.

Continuum is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and of other relevant US statutory bodies authorized to verify and ensure compliance with the Privacy Shield Principles.

VII. For users in Australia.

We comply with the Australian Privacy Principles as set out in the Privacy Act 1988 (Cth) (“Privacy Act”) regarding the collection, storage, use and disclosure of Personal Information from Australian users.

In addition to the uses set out in the section titled “How We Use Information Collected through Our Services and Continuum Websites”, we may also use your information, including Personal Information, for a secondary purpose that is related to a purpose for which we collected it, where you would reasonably expect us to use your personal information for that secondary purpose.

Under the Privacy Act, we have an obligation (the “Obligation”) to take reasonable steps, in the circumstances, before disclosing Personal Information to an overseas recipient to ensure that the overseas recipient does not breach privacy laws in relation to that information. However, should we obtain your consent to disclose your Personal Information to an overseas recipient, the Obligation does not apply. In obtaining your consent, we will not be accountable and you will not be able to seek redress against us under the Privacy Act if the overseas recipient handles your Personal Information in breach of the Australian Privacy Principles (“APPs”) under the Privacy Act. In providing your consent under this Privacy Policy, you acknowledge and agree to the risks associated with the disclosure of your Personal Information overseas. These risks may include the overseas recipient not being subject to any privacy obligations or privacy principles similar to the APPs and the overseas recipient being subject to foreign law that could compel the disclosure of your Personal Information to a third party, such as an overseas authority.

If you are a user in Australia and wish to access, correct or update your information in accordance with section III, Continuum may refuse certain requests but only in circumstances where this is permitted under the Privacy Act.

VIII. Accessing Your Information

We acknowledge the individual’s right to access their personal data. You can access and update your account information by logging into your account at https://control.itsupport247.net/. As soon as practically possible after your request is received, we will disclose to you all your Personal Information that we keep.

If you wish to have your Personal Information deleted please contact privacy@continuum.net to request that we do so.

Promptly after receiving your request, all Personal Information stored in databases we actively use and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as reasonably practicable.

IX. Children’s Privacy

We do not knowingly collect, store, or use information from children, including those under the age of 13.  If you are under the age of 13, you may not submit any information through the Continuum Websites or Services. If you have reason to believe that a child under the age of 13 has provided information to us through the Continuum Websites or Services, please contact us and we will endeavor to delete that information from our databases.

X. Do Not Track

The Continuum Websites currently do not respond to “Do Not Track” (DNT) signals, and operate as described in this Privacy Policy whether or not a DNT signal is received.

XI. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices from time to time.  If we decide to change this Privacy Policy, we will post the changes on this page so visitors to the Continuum Website and our clients and the users of their IT systems are aware of our practices, and we will change the “Last Updated” date above.  If we make a material change to our information practices, such as to how we use Personal Information, we will make reasonable efforts to provide notice on our website and/or through our clients and obtain consent to any such uses as may be required by law.

XII. Complaints and How to Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our information practices, please email us at privacy@continuum.net.

In compliance with the EU-US Privacy Shield Principles, we are committed to resolving 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 us by email at privacy@continuum.net. If you don’t receive adequate resolution of a privacy-related problem, you may write to our Chief Information Security Officer at:

Hunter Smith

Chief Information Security Officer

Continuum Managed Services Holdco

99 High St

Suite 3100

Boston, MA USA

02110

 

For EU Individuals: If a complaint cannot be resolved by any of the mechanisms described above, you also have a right, under certain conditions, to invoke binding arbitration under the Privacy Shield Panel in compliance with the EU-US Privacy Shield. If you want to initiate this arbitration procedure, you are required to first formally notify us of your intention to do so by writing to privacy@continuum.net. Please remember to include a summary of the steps you have already taken to resolve your complaint and a description of the alleged violation.

Specifically, if you are a European Union individual and a complaint cannot be resolved through Continuum’s internal process, we have further committed to refer such complaints, under the EU-US Privacy Shield Principles to utilize JAMS as an alternative dispute resolution provider. Information regarding JAMS and the process for initiating a claim can be found at https://www.jamsadr.com/eu-us-privacy-shield.

For Australian individuals: if a complaint cannot be resolved by any of the mechanisms described above or for more information on your privacy rights, you may contact the Office of the Australian Information Commissioner at:

 

Phone: 1300 363 992. If calling from outside Australia: +61 2 9284 9749

Fax: +61 2 9284 9666

Email: enquiries@oaic.gov.au 

Address: GPO Box 5218, Sydney NSW 2001