Sprintserve Net LLC (hereinafter the
"Company") respects individual privacy and values the confidence
of their customers, employees, consumers, business partners and
others. Not only does the Company strives to collect, use and
disclose personal information in a manner consistent with the
laws of the countries in which it does business, but it also
pride themselves on upholding the highest ethical standards in
"Policy") sets forth the privacy principles that the Company
follows with respect to personal information transferred from
the European Union (EU) to the
The United States Department of Commerce and
the European Commission have agreed on a set of data protection
principles and frequently asked questions (the "Safe Harbor
Principles") to enable
applies to all personal information received by The Company in the
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that uses personal information provided by The Company to perform tasks on behalf of and under the instructions of The Company.
"SP" means Sprintserve Net LLC; a Delaware-incorporated LLC in the United States of America, its respective successors, subsidiaries, divisions and groups in the United States..
"Personal information" means any information or set of information that identifies or could be used by or on behalf of The Company to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, The Company will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
"The Company" means Sprintserve
Net LLC and their respective successors, subsidiaries, divisions and
groups in the
The privacy principles in this Policy are based on the Safe Harbor Principles.
NOTICE: Where the Company collects personal information directly from individuals in the EU, 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, and the choices and means, if any, the Company offers individuals 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 the information for a purpose other than that for which it was originally collected.
Where the Company receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use 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 (opt-in) consent 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 their 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 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding. Where the Company becomes aware 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's Privacy Office at the address given below. The Company will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between the Company and the complainant, the Company have agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.
The Company sees the Internet and the use of
other technologies as valuable tools for communicating and
interacting with consumers, employees, healthcare professionals,
business partners, and others. The Company recognizes the importance
of maintaining the privacy of information collected online and has
treatment of personal information collected through web sites that
it operates. With respect to personal information that is
transferred from the EU to the
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by the Company to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation.
Questions or comments regarding this Policy should be submitted to the following person by mail as follows:
Sprintserve Net LLC
Email address: silver [at] sprintserve.net
CHANGES TO THIS
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the Company's web page www.sprintserve.net.
EFFECTIVE DATE: June 1st, 2009