The United States Department of Commerce and the European Commission have agreed on a set of data protection principles (the “U.S.-EU Safe Harbor Principles”) and frequently asked questions (collectively the “U.S.-EU Safe Harbor Framework”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. The EEA also has recognized the U.S. Safe Harbor as providing adequate data protection. The United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of data protection principles (the “U.S.-Swiss Safe Harbor Principles”) and frequently asked questions (collectively the “U.S.-Swiss Safe Harbor Framework) to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States. Consistent with its commitment to protect personal privacy, Verian adheres to the U.S.-EU and U.S.-Swiss Safe Harbor Principles (hereinafter “Safe Harbor Principles”).
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Verian or to which Verian discloses personal information for use on Verian’s behalf.
“Verian” means Verian Company, its successors, subsidiaries, divisions and groups in the United States.
“Personal Information” means any information or set of information that identifies or is used by or on behalf of Verian 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, Verian 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 privacy principles in this Policy are based on the Safe Harbor Principles.
NOTICE: Where Verian 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 and the choices and means, if any, Verian 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 Verian, or as soon as practicable thereafter, and in any event before Verian uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a non-agent third party.
Where Verian receives personal information from its subsidiaries, 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: For personal information, Verian will offer individuals the opportunity to choose (opt-in) 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, Verian 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.
Verian will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY: Verian will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Verian will take reasonable steps to ensure that personal information that is relevant to fulfill the purpose of the request and will retain such information no longer than appropriate to fulfill the purpose of the request.
TRANSFERS TO AGENTS: Verian 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 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where Verian has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Verian will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION:
Verian limits the data collected to what is required to deliver value through our products and services requested by the customer. In addition, we collect data that protects the customer against fraud, and fulfills legal and regulatory requirements. This data includes the following:
- Information we receive from you from our corporate website, via the service you have purchased, and any other information you provide to us verbally or in writing
- Information about your transactions and communications with us
- Information from public records accessed in the ordinary course of business
Verian has put safeguards in place to protect the security and confidentiality of your information.
- Only Verian employees who need access to your information to do their jobs are granted access to such data. These Employees are required to maintain the confidentiality of all customer information.
- Verian complies with industry standards for maintaining physical, electronic and procedural safeguards that protect the safety of your company’s information. We routinely test our information systems and website to ensure that unauthorized access does not occur.
Privacy policies will remain in effect even after closing or cancelling an account.
Safe Harbor Program
- Verian is a participant in the Safe Harbor program developed by the U.S. Department of Commerce and (1) the European Union and (2) Switzerland, respectively. Verian has certified that it adheres to the Safe Harbor Privacy Principles agreed upon by the U.S. and (1) the European Union and (2) Switzerland, respectively. For more information about the Safe Harbor program and to view our certification, visit the U.S. Department of Commerce’s Safe Harbor Web Site. (http://www.export.gov/safeharbor/)
- In compliance with the US-EU and US-Swiss Safe Harbor Principles, we endeavor to resolve all complaints about privacy and the collection or use of customer information. If you have questions about our participation in the Safe Harbor program or have a compliant, please send an email to email@example.com.
Verian takes every reasonable precaution to protect your information.
- When you submit information to us through our web site, your information is protected both on-line and off-line.
- All data transferred to/from the Verian internal network, from/to an external entity, is encrypted to industry standards (256 bit encryption). Note that messages you send to us by Internet e-mail may not be secure.
- We maintain appropriate physical, electronic and procedural safeguards to ensure the security, integrity and privacy of your personal information within our company.
- Only those employees who require your organization’s information to perform a specific job are granted access to your organization’s identifiable information. Furthermore, all employees are kept up-to-date on our security and privacy practices.
- If you have any questions about our security safeguards, please contact us at firstname.lastname@example.org.
Use of Internet Browser Cookies
- Verian may use Internet browser “cookies.”
- A cookie is a small line of text that is stored by your browser on your computer’s hard drive.
- Our cookies do not contain any personally identifiable information.
- We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) to track visitor activity.
- We will post any changes to this on our web site and notify you through your billing contact email.
Safe Harbor Certification
Verian’s hosting partner Amazon Web Services’ Safe Harbor certification can be found at http://aws.amazon.com/privacy.