We self-certify compliance with
“Personal Information” or “Information” means information that: (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.
“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
SAFE HARBOR PRINCIPLES
Company shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which the Company discloses or may disclose that Information. Company shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which it was originally collected.
The Company will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, the Company will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Company shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.
Prior to disclosing Personal Information to a third party, Company shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Company shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.
Company shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Company cannot guarantee the security of Information on or transmitted via the Internet.
Company shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Company shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.
Company shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider.
The Company will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information by reference to the principles contained in this Policy. For complaints that cannot be resolved between the Company and the complainant, we have agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:
- for disputes involving personal information received by the Company from the EEA, we have agreed to register with the United Kingdom’s Information Commissioner’s Office (https://ico.org.uk/Global/contact_us) for dispute resolution. Individuals who submit a question or concern to us who do not receive acknowledgment from us of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the UK ICO on the Internet https://ico.org.uk/Global/contact_us on the telephone at 0303 123 1113, or by mail. Inquiries by mail or fax should identify the Company as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether the ICO may share the details of the inquiry with the Company. The ICO will act as a liaison to the Company to resolve these disputes.
Information Subject to Other Policies
Questions, comments or complaints regarding the Company’s Safe Harbor Policy or data collection and processing practices can be emailed to:
Effective Date: 10 September 2014
Collection of personal information for propagating business
From time to time, we may request Personal Information from you to get valuable feedback from your experience on our website. In addition, we may also use your personal information for other business purposes or in order to help serve you better, such as informing you of new services, products, or alliances that could help you in your business. Your posting of any such Personal Information is strictly up to you, but please understand that this is a website accessed by the public. Therefore, do NOT post any information that is confidential and/or proprietary. While you can visit our site without disclosing any Personal Information, there are web pages that require such information to complete certain functions, thus these web pages may not be available to you if you decide not to reveal the information requested. We will take reasonable steps to ensure that your Personal Information is accurate and complete.
Collecting information for on-line surveys
At times, we conduct online surveys to better understand the needs and profile of our visitors. When we conduct a survey, we will inform you about how we will use the information prior to your taking the survey. If you do not want to participate in the survey, you may refrain from contributing to it at your own discretion.
Our Website may use a technology known as web beacons - sometimes called single-pixel gifs - that allow this site to collect web log information. A web beacon is a graphic on a web page or in an email message designed to track pages viewed or messages opened. Web log information is gathered when you visit one of our Websites by the computer that hosts our Website (called a “webserver”). The webserver automatically recognizes some non-personal information, such as the date and time you visited our site, the pages you visited, the website you came from, the type of browser you are using (e.g., Internet Explorer), the type of operating system you are using (e.g., Windows 7), and the domain name and address of your Internet service provider (e.g., AOL). We may also include web beacons in promotional email messages in order to determine whether messages have been opened.
Our Website uses a technology called a “cookie”. A cookie is a piece of information that our webserver sends to your computer (actually to your browser file) when you access a website. Then when you come back our site will detect whether you have one of our cookies on your computer. Our cookies help provide additional functionality to the site and help us analyze site usage more accurately. For instance, our site may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to the site.
Our Website uses Internet Protocol (IP) Addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet. Generally, an IP address changes each time you connect to the Internet (it is a “dynamic” address). Note, however, that if you have a broadband connection, depending on your individual circumstance, it is possible that your IP Address that we collect, or even perhaps a cookie we use, may contain information that could be deemed identifiable. This is because with some broadband connections your IP Address doesn’t change (it is “static”) and could be associated with your personal computer. We use your IP address to report aggregate information on use and to help improve the Website.
You should be aware that this site is not intended for, or designed to attract, individuals under the age of 18. We do not collect personally identifiable information from any person we actually know is an individual under the age of 18.
Areas of this Website that collect your Information use industry standard secure socket layer encryption (SSL); however, to take advantage of this your browser must support encryption protection (found in Internet Explorer release 3.0 and above).
Disclosure to third parties
We may share your Personal Information with agents, contractors or partners of the Company in connection with services that these individuals or entities perform for, or with, the Company. These agents, contractors or partners are restricted from using this data in any way other than to provide services for the Company, or services for the collaboration in which they and the Company are engaged (for example, some of our products are developed and marketed through joint agreements with other companies). We may, for example, provide your information to agents, contractors or partners for hosting our databases, for data processing services, or so that they can mail you information that you requested. You may remove yourself from any such list or notification at any time.
The Company reserves the right to share your Personal Information to respond to duly authorized information requests of governmental authorities or where required by law. In exceptionally rare circumstances where national, state, or company security is at issue (such as with the World Trade Center terrorist act in September, 2001), The Company reserves the right to share our entire database of visitors and customers with appropriate governmental authorities.
We may also be required to disclose your Personal Information in the event of a legal investigation or any such other process where we are required to do so by applicable law or where we have to establish our legal rights or where disclosure is required to prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person.
As a convenience to our visitors, this Website currently contains links to a number of sites that we believe may offer useful information. The policies and procedures we described here do not apply to those sites. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies.