NOTICE: Where the Company collects Personal Information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses Personal Information about them, the types of non-agent third parties to which the Company discloses that information, the choices and means, if any, the Company offers individuals for limiting the use and disclosure of Personal Information about them, and how to contact the Company. 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 that for which it was originally collected.
Where the Company receives Personal Information from its affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.
CHOICE: The Company will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) 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 and explicitly consent (opt-in) to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
The Company will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY: The Company will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. The Company will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: The Company will obtain assurances from its Agents that they will safeguard Personal Information consistently with this Policy. Examples of appropriate assurances that may be provided by Agents include: a contract obligating the Agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive, or Safe Harbor certification by the Agent. Where the Company has knowledge that an Agent is using or disclosing Personal Information in a manner contrary to this Policy, the Company will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, the Company will grant individuals reasonable access to Personal Information that it holds about them. In addition, the Company will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: The Company will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT: The Company will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that the Company determines is in violation of this policy will be subject to disciplinary action, up to and including termination of employment.
DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the Company Office at the address given below. 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, the Company has 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 information about AAA or the operation of the AAA arbitration dispute resolution process, visit AAA on the Internet at www.adr.org. The AAA arbitration dispute resolution process shall be conducted in English.
LIMITATION ON APPLICATION OF PRINCIPLES
Information Security Department
EFFECTIVE DATE: April 2013
To learn more about the Safe Harbor program, and to view the Company’s certification, please visit http://www.export.gov/safeharbor/.