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Privacy policy

HudsonAnalytix, Inc., along with its subsidiaries, Hudson Marine Management Services, HudsonTrident, HudsonTactix, HudsonSystems, Hudson Dynamix, Hudson Analytix Hellas Marine Consultants Limited Company, and Hudson Marine Management Services, S.R.L., collectively referred to as “Hudson,” has adopted this Privacy Shield Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that Hudson obtains from Individual Customers, potential Individual Customers, and Employees located in the European Union (EU) and Switzerland.

Hudson complies with the US-EU Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, processing, and retention of personal information from Individual Customers, Potential Customers, and Employees in the EU member countries and Switzerland. Hudson has certified that we adhere 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 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.
The Federal Trade Commission (FTC) has jurisdiction over Hudson’s compliance with the Privacy Shield.
All Hudson employees who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.
Capitalized terms are defined in Section 14 of this Policy.

    1.      Scope

This Policy applies to the processing of Individual Customer Personal Data that Hudson receives in the United States concerning Individual Customers who reside in the EU and Switzerland. Hudson provides products and services to businesses and consumers.

This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)

    2.      Responsibilities and Management

Hudson has designated The Chief Technology Officer (CTO) to oversee our information security program, including our compliance with the EU and Swiss Privacy Shield program. The CTO shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to info@hudsonanalytix.com

Hudson will continually maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that we collect. Hudson personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that Hudson has undertaken to protect Personal Data.

    3.      Renewal/Verification

Hudson will renew our US-EU Privacy Shield and Swiss-US Privacy Shield certifications annually, unless we subsequently determine that we no longer need such certification or if we employ a different adequacy mechanism.

Prior to the re-certification, Hudson will conduct an in-house verification to ensure that our attestations and assertions about our treatment of Individual Customer Personal Data are accurate and that we have appropriately implemented these practices. Specifically, as part of the verification process, Hudson will undertake the following:

            A.    Review the Privacy Shield policy and our publicly posted website privacy policy to ensure that these policies accurately describe the practices regarding the collection of Individual Customer Personal Data. 
            B.    Ensure that the publicly posted privacy policy informs Individual Customers of Hudson’s participation in the US-EU Privacy Shield and US-Swiss Privacy Shield programs and where to obtain a copy of additional information (e.g., a copy of this Policy).
            C.   Ensure that this Policy continues to comply with the Privacy Shield principles
            D.   Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process. Hudson may do so through our publicly posted website, Individual Customer contract, or both.
            E.   Review our processes and procedures for training Employees about Hudson’s participation in the Privacy Shield programs and the appropriate handling of Personal Data.


Hudson will prepare an internal verification statement on an annual basis.

    4.      Collection and Use of Personal Data

Hudson provides various solutions to our Individual Customers who purchase our products and services. Hudson collects Personal Data from Individual Customers when they purchase our products, register with our website, log in to their account, complete surveys, request information, or otherwise communicate with us.
The Personal Data that Hudson collects may vary based on the Individual Customer's interaction with our employees, website, and request for our services. As a general matter, Hudson collects the following types of Personal Data from our Individual Customers or Employees including: contact information, a contact person's name, date of birth, passport number, work email address, work mailing address, work telephone number, title, and company name; and health information, including medical records and reports, photographs, test results, and medical bills and invoices.
When Individual Customers use Hudson’s services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our various websites and software to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website or via email to a Hudson Employee.
We use the information that we collect from Individual Customers and their employees for providing the services that the Individual Customer has requested. These can include processing of claims and claims-related matters; the sale of products and services; managing transactions; reporting to our Customers, government agencies, insurers, and other organizations to which we are legally obligated to disclose personal information; invoicing; renewals; and other operations related to providing services and products to the Individual Customer.
In our capacity as a service-provider, we will receive, store, and/or process Personal Data. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of our partners and/or agents. The information that we collect from our Individual Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Individual Customer, and as otherwise requested by our partner and/or agent.
Hudson uses Personal Data that we collect directly from our Individual Customers and their employees and their partners indirectly in our role as a service provider for the following business purposes, without limitation:

Maintaining and supporting our products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to an Individual Customer);

          A.     Satisfying governmental reporting, tax, and other requirements (e.g., import/export);
          B.     Providing our services as related to insurance claims and medical claims of its customers’ employees;
          C.     Storing and processing data, including Personal Data, in computer databases and servers located in the United States;
          D.     Verifying identity (e.g., for online access to accounts);
          E.     As requested by the Individual Customer;
          F.     For other business-related purposes permitted or required under applicable local law and regulation;
          G.    And as otherwise required by law.


Hudson does not disclose personal information to Third Parties for purposes that are materially different than what it was originally collected for. Should this change in the future, we will provide individuals with the option to opt out.

5.      Disclosures/Onward Transfers of Data

Except as otherwise provided herein, Hudson discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.
Hudson may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, Hudson may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by Hudson and they must either:

         A.     Comply with the Privacy Shield principles or another mechanism permitted by the applicable EU and Swiss data protection law(s) for transfers and processing of Personal Data;
         B.     Or agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy.


Hudson also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that Hudson 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. Hudson is liable for appropriate onward transfers of personal data to third parties.

6.      Sensitive Data

Hudson collects Sensitive Data from its Individual Customers and their employees and family members about Data Subjects in the form of personal health information, including medical records, medical reports, passport numbers, dates of birth, addresses, photographs, test results, proposed treatment plans, and medical information contained in emails, .

7.      Data Integrity and Security

Hudson uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Hudson has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to Hudson electronic information systems requires user authentication via password or similar means. Hudson also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.

Further, Hudson uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.

8.      Notification

Hudson notifies Individual Customers about our adherence to the EU-US Privacy Shield and Swiss-US Privacy Shield principles through our publicly posted website privacy policy, available at: HudsonAnalytix Privacy Policy and assume Individual Customers’ approval and adherence to the current policy when they provide their information to us in the transactional process.

9.      Accessing Personal Data

Hudson personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.

10.  Right to Access, Change, or Delete Personal Data

Individual Customers have the following rights to access, change, or delete their Personal Data.

          A.     Right to Access. Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which Hudson collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and Hudson policies. Upon reasonable request and as required by the Privacy Shield principles, Hudson allows Individual Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by contacting Hudson by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to Hudson.
          B.     Requests for Personal Data. Hudson will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If Hudson receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, Hudson will refer such Data Subject to the Individual Customer.
         C.     Satisfying Requests for Access, Modifications, and Corrections. Hudson will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

11.  Changes to this Policy

This Policy may be amended from time to time, consistent with the US-EU and US-Swiss Privacy Shield Principles and applicable data protection and privacy laws and principles. Hudson will make employees aware of changes to this Policy either by posting to through email, or other means. Hudson will notify Individual Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.

12.  Questions or Complaints

EU and Swiss Individual customers may contact Hudson with questions or complaints concerning this Policy at the following address: info@hudsonanalytix.com

13.  Enforcement and Dispute Resolution

In compliance with the US-EU and Swiss-US Privacy Shield Principles, Hudson commits to resolve complaints about your privacy and our collection or use of your personal information. EU and Swiss individuals with questions or concerns about the use of their Personal Data should contact us at: info@hudsonanalytix.com.

If an Individual Customer's question or concern cannot be satisfied through this process, Hudson has further committed to satisfy the requirement in points (a)(i) and (a)(iii) of the Privacy Shield Recourse, Enforcement and Liability Principle by committing to cooperate with the relevant Data Protection Authority(ies) (DPA). Hudson will cooperate with the DPAs in the investigation and resolution of complaints brought under the Privacy Shield and will comply with any advice given by the DPAs where the DPAs take the view that the organization needs to take specific action to comply with the Privacy Shield Principles, including remedial or compensatory measures for the benefit of individuals affected by any non-compliance with the Principles, and will provide the DPAs with written confirmation that such action has been taken.
Finally, as a last resort and in limited situations, EU and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
Hudson commits to cooperate with EU and Swiss DPAs and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

14.  Defined Terms

Capitalized terms in this Privacy Policy have the following meanings:

"Individual Customer" means an individual or business from an EU member state or Switzerland that purchases goods or services from Hudson. The term also shall include any individual agent or representative of an individual customer of Hudson and all employees of Hudson where Hudson has obtained his or her Personal Data from such Individual Customer as part of its business relationship with Hudson.
"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.
"Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of Hudson or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.
"Europe" or "European" refers to a country in the European Union.
"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term "person" includes both a natural person and a legal entity, regardless of the form of the legal entity.
"Sensitive Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
"Third Party" means any individual or entity that is neither Hudson nor an Hudson employee, agent, contractor, or representative.