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Safe Harbor Policy
Data Gathering Activities
The Company gathers data on individuals in a variety of ways both on-line and off-line in the course of its business. This occurs principally when the Company gathers information from its customers in order to bill to the customers the services performed by the Company for such customers.
“Personal Information” or “Information” means information that (1) is transferred from the EU or Switzerland 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. Personal information does not include information that is encoded, anonymized, or publicly available information that has not been combined with non-public personal information. Personal Information does not include information that pertains to or is about a specific individual, but from which that individual could not reasonably be identified.
“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.
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. This obligation with regard to onward transfers does not apply to disclosures required by law, regulation, or judicial or administrative order, to disclosures made at the request of law enforcement authorities investigating criminal activities, to disclosures to credit bureaus, or to the Company’s professional advisers such as its lawyers and accountants.
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. The individual seeking access to or to amend such information will need to provide sufficient identifying information, such as name, address, birth date, and other identifying information that the Company may request as a security precaution.
Information Subject to Other Policies
Questions, comments or complaints regarding the Company’s Safe Harbor Policy or data collection and processing practices can be mailed or emailed to:
Attn: Legal Department
1321 W. 12th Street
Los Angeles, CA 90015
Effective date: September 1, 2014