This Statement is effective as of September 29, 2016.

This IBM Privacy Shield Privacy Policy for Cloud Services (the “Policy”) applies to the IBM Infrastructure-as-a-Service, Platform-as-a-Service, Software-as-a-Service, and other hosted offerings that are Privacy Shield certified (“Privacy Shield-Certified Cloud Services”). A list of these offerings is provided below; if an offering is not on this list, it is not covered by the Privacy Shield.

As the Privacy Shield only applies to personal data transferred from European Economic Area (EEA) to the United States, this Statement only applies to personal data from the EEA that is hosted in the United States through the Privacy Shield-Certified Cloud Services. This Policy does not apply when clients choose to have their offering content hosted in other countries.

IBM’s Privacy Shield-Certified Cloud Services process content (which may include the personal data of individual end users) on behalf of enterprise clients. In this scenario, and as provided below, IBM may direct inquiries from individual end users to the enterprise client that oversees the use of their personal data.

All personal data received from the EU in connection with Privacy Shield-Certified Cloud Services is subject to the Privacy Shield principles, which apply to all IBM affiliates that process personal data associated with Privacy Shield-Certified Cloud Services.

To learn more about the Privacy Shield Program, or to view the certification applicable to certain IBM Cloud Services, please visit www.privacyshield.gov.

Personal Data: Types and Purpose for Use

The types of personal data that Privacy Shield-Certified Cloud Services collect will vary based on the type and nature of each offering, and is described in its offering documentation (searchable via this link) or as otherwise provided by IBM. IBM uses such personal data as needed to deliver the Cloud Service, along with additional purposes that may be described in the corresponding TD or Attachment.

Use of Subprocessors

IBM may use processors and subprocessors (including personnel and resources) in locations worldwide to deliver the Cloud Services. A list of subprocessors is available upon request. If IBM subcontracts the performance of any of the Cloud Services pursuant to any Attachment or TD, IBM will be liable to the Client for the acts and omissions of IBM subcontractors as if they were the acts or omissions of IBM under the agreement governing the Cloud Services (subject to the limits and exclusions of liability).

Regulatory Authority and Disclosures

IBM is subject to investigatory and enforcement powers of the Federal Trade Commission in the United States in connection with its Privacy Shield program. IBM may also be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Additional Information for End Users

If end users have any questions or complaints concerning IBM’s processing of personal data on behalf of an IBM enterprise client, they are invited to contact the enterprise client directly, or they may contact IBM at shield@us.ibm.com. End users who wish to access the personal data that IBM hosts on behalf of an enterprise client, or to make choices concerning their data, are invited to contact the enterprise client directly.

Dispute Resolution

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. In addition, and as described in the Privacy Shield Principles, you may also have the option of invoking binding arbitration after other dispute resolution procedures have been exhausted.

Account Data

Account data -- i.e. all information about IBM’s clients or their users provided to or collected by IBM (including through tracking and other technologies, such as cookies) – is covered by the IBM Online Privacy Statement, available at www.ibm.com/privacy/details/us/en/.

Privacy Shield-Certified Cloud Services

Analytics

  • IBM Algo One Managed Data Services on Cloud
  • IBM Algorithmics Risk Content and Data Services on Cloud
  • IBM Algorithmics Risk Services on Cloud
  • IBM Cognos Analytics on Cloud
  • IBM Cognos Controller
  • IBM Cognos Disclosure Management on Cloud
  • IBM Content Manager Enterprise Edition on Cloud
  • IBM Decision Optimization on Cloud
  • IBM Incentive Compensation Management - Sales Performance Management on Cloud
  • IBM Modeler Gold on Cloud
  • IBM Open Pages
  • IBM Regulatory Compliance Analytics
  • IBM SPSS Statistics Subscription
  • IBM TM1/Planning Analytics
  • IBM Watson Analytics
  • IBM Watson Analytics for Social Media

Cloud

  • IBM Bluemix Infrastructure Services (formerly known as SoftLayer for Bare Metal, Virtual & Storage)
  • IBM Bluemix Platform
  • IBM Bluemix Private Cloud – Dedicated and Local
  • IBM Bluemix Private Cloud with Red Hat
  • IBM Bluemix: IBM Object Storage for Bluemix (IaaS)
  • IBM Cloud for SAP Applications
  • IBM Cloud for Oracle Solutions
  • IBM Cloud Managed Services
  • IBM Cloud Object Storage Dedicated
  • IBM Cloud Object Storage Select
  • IBM PureApplication
  • SoftLayer for Bare Metal, Virtual, and Storage (now known as IBM Bluemix Infrastructure Services)

Hybrid Cloud: Dev Ops/Hybrid Cloud Mgmt

  • IBM Alert Notification
  • IBM Control Desk on Cloud
  • IBM Performance Management on Cloud
  • IBM Predictive Insights on Cloud
  • IBM Runbook Automation

Hybrid Cloud: Hybrid Integration

  • IBM API Connect on Bluemix
  • IBM App Connect
  • IBM App Connect Professional (formerly known as IBM Cast Iron Live)
  • IBM Aspera Files
  • IBM Cloud High-Speed Transfer Service
  • IBM Integration Bus on Cloud
  • IBM Message Hub
  • IBM Secure Gateway on Bluemix

Hybrid Cloud: Smarter Process

  • IBM Blueworks Live
  • IBM Business Process Manager Hybrid Entitlement
  • IBM Business Process Manager on Cloud
  • IBM Business Rules for Bluemix
  • IBM Operational Decision Management on Cloud

IBM Analytics Platform & Cloud Data Services

  • IBM Analytics for Apache Spark
  • IBM BigInsights on Cloud
  • IBM Bluemix Data Connect
  • IBM Bluemix Lift
  • IBM Case Manager on Cloud
  • IBM Content Foundation on Cloud
  • IBM Content Manager OnDemand on Cloud
  • IBM dashDB for Analytics
  • IBM dashDB for Transactions
  • IBM Datacap on Cloud
  • IBM DB2 on Cloud
  • IBM Geospatial Analytics for Bluemix
  • IBM Informix on Cloud
  • IBM Master Data Management on Cloud
  • IBM Streaming Analytics

Industry Solutions

  • IBM Client Insight for Wealth Management on Cloud
  • IBM Customer Insight for Banking on Cloud
  • IBM Customer Insight for Insurance on Cloud
  • IBM Surveillance Insight for Financial Services on Cloud

Internet of Things: Automotive

  • IBM IoT for Automotive

Internet of Things: Continuous Engineering

  • IBM Collaborative Lifecycle Management on Cloud
  • IBM DOORS Next Generation on Cloud
  • IBM Engineering Lifecycle Manager on Cloud
  • IBM IoT Continuous Engineering on Cloud
  • IBM Rational Quality Manager on Cloud
  • IBM Rhapsody Design Manager on Cloud
  • IBM Team Concert on Cloud
  • IBM Track and Plan on Cloud

Internet of Things: Enterprise Asset Mgmt

  • IBM Enterprise Asset Management Flex on Cloud (Maximo)
  • IBM Enterprise Asset Management Fundamentals on Cloud (Maximo)
  • IBM Enterprise Asset Management on Cloud (Maximo)
  • IBM Facilities and Real Estate Management on Cloud (TRIRIGA)
  • IBM Facilities and Real Estate Management on Cloud Flex (TRIRIGA)

Internet of Things: Manufacturing

  • IBM Prescriptive Maintenance for Manufacturing
  • IBM Prescriptive Quality for Manufacturing (formerly known as “IBM Predictive Quality on Cloud”)
  • IBM Prescriptive Warranty for Manufacturing (formerly known as “IBM Predictive Warranty on Cloud”)

Internet of Things: Platform

  • IBM IoT for Electronics
  • IBM Insights Foundation for Energy on Cloud
  • IBM Watson IoT Context Mapping
  • IBM Watson IoT Driver Behavior
  • IBM Watson IoT Platform
  • IBM Watson IoT Platform Analytics Real-Time Insights

Internet of Things: Predictive Maintenance

  • IBM Predictive Solutions Foundation on Cloud
    IBM Predictive Solutions Foundation on Cloud includes:
    1. IBM Predictive Maintenance on Cloud

Security

  • IBM Cloud Identity Service
  • IBM Cloud Security Enforcer
  • IBM MaaS360
  • IBM Managed Security Services (MSS)
    • The Privacy Shield certification for Managed Security Services includes both cloud services and managed services within the offering
  • IBM QRadar on Cloud (Formerly IBM Security Intelligence on Cloud)
  • IBM Security Trusteer Mobile Browser
  • IBM Security Trusteer Mobile SDK
  • IBM Security Trusteer Pinpoint
    IBM Security Trusteer Pinpoint includes:
    1. IBM Security Trusteer Pinpoint Detect
    2. IBM Security Trusteer Pinpoint Criminal Detection
    3. IBM Security Trusteer Pinpoint Malware Detection
  • IBM Security Trusteer Rapport
  • IBM Security Trusteer Rapport Remediation
  • IBM Single Sign On for Bluemix
  • IBM X-Force Exchange

Social

  • IBM Kenexa Assess on Cloud
  • IBM Kenexa LCMS Premiere on Cloud
  • IBM Kenexa LMS on Cloud
  • IBM Kenexa Skills Manager
  • IBM Kenexa Talent Acquisition Suite
  • IBM Talent Insights

Social and Email

  • IBM Connections Cloud
    IBM Connections Cloud includes:
    1. IBM Connections S1
    2. IBM Connections S2
    3. IBM Collaboration Social Cloud
    4. IBM Connections Chat Cloud
    5. IBM Connections Meetings Cloud
    6. IBM Connections Archive Essentials
    7. IBM Connections Docs Cloud
    8. IBM Notes Traveler
    9. IBM Web Mail Cloud
    10. IBM SmartCloud Audio for Meetings
    11. IBM SmartCloud Notes
    12. IBM Connections Files Cloud
  • IBM Verse

Systems

  • IBM Spectrum Control Storage Insights

Watson

  • IBM Clinical Trial Management
  • IBM Watson for Genomics
  • IBM Watson Platform for Health (formerly known as Watson Health Core)
  • IBM Watson for Oncology

Watson Customer Engagement (formerly Commerce)

  • IBM AdTarget Data Feed for Partners
  • IBM B2B Cloud Services
  • IBM Behavior Based Fan Insight
  • IBM Commerce Insights
  • IBM Commerce on Cloud
  • IBM Commerce Services
  • IBM Configure Price Quote Service
  • IBM Coremetrics AdTarget Data Feed for Partners
  • IBM Coremetrics Web Analytics
  • IBM Customer Experience Analytics
  • IBM Demand Insight for Retail
  • IBM Digital Analytics
  • IBM Digital Content Hub
  • IBM Digital Data Exchange
  • IBM Digital Experience on Cloud (DXoC)
  • IBM eMessage
  • IBM Emptoris Contract Management on Cloud
  • IBM Emptoris Program Management on Cloud
  • IBM Emptoris Services Procurement
  • IBM Emptoris Sourcing on Cloud
  • IBM Emptoris Spend Analysis on Cloud
  • IBM Emptoris Strategic Supply Management
  • IBM Emptoris Strategic Supply Management Managed Cloud Delivery
  • IBM Emptoris Supplier Lifecycle Management on Cloud
  • IBM Marketing Cloud Engage (f.k.a. IBM Silverpop Engage)
  • IBM Marketing Cloud for Group Messaging
  • IBM Marketing Cloud Peformance Insights
  • IBM Marketing Cloud Social Audiences
  • IBM Marketing Operations onDemand (MOOD)
  • IBM Mobile Application Content Manager Bluemix service
  • IBM Mobile Customer Engagement (f.k.a IBM Xtify 2.x platform)
  • IBM Order Management Service
  • IBM Partner Engagement Manager
  • IBM Pay
  • IBM Payments Gateway
  • IBM Social Media Insight for Consumer Products
  • IBM Social Media Insight for Retail
  • IBM Sterling B2B Services – File Transfer Service
  • IBM Sterling B2B Services Collaboration Network
  • IBM Sterling B2B Services Reporting & Analytics
  • IBM Sterling e-Invoicing
  • IBM Sterling Web Forms
  • IBM Tealeaf Customer Experience on Cloud
  • IBM Universal Behavior Exchange
  • IBM Watson Marketing Insights (formerly known as IBM Predictive Customer Analytics on Cloud)