Effective Date: 7 March 2007
European Safe Harbor Privacy Policy
Initiate Systems strives to collect, use and disclose personally identifiable information in a manner consistent with the laws of the countries in which it does business and has a tradition of upholding the highest ethical standards in its business practices. Initiate Systems abides by the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission and the Frequently Asked Questions (FAQs) issued by the Department of Commerce on July 21, 2000. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Initiate Systems follows with respect to transfers of personal information anywhere in the world, including transfers from the European Economic Area (EEA) to the United States.
The following privacy principles apply solely to the extent that Initiate Systems collects personally identifiable information directly from individuals.
Notice
Initiate Systems will inform individuals about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which Initiate Systems discloses that information, and the choices and means, if any, Initiate Systems 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 Initiate Systems, or as soon as practicable thereafter, and in any event before Initiate Systems uses the information for a purpose other than that for which it was originally collected. As discussed in the Privacy Policy, Initiate Systems will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with a warrant, subpoena, court order or other legal process served on Initiate Systems or the Initiate Systems website; (b) protect and defend the rights, property or security of Initiate Systems; and (c) act under exigent circumstances to protect the safety of users of Initiate Systems, or the public.
Choice
Initiate Systems will offer individuals the opportunity to choose (opt out) of whether their personally identifiable 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, Initiate Systems 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.
Initiate Systems will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.
In order to request that Initiate Systems not use an individual’s non-public personally identifiable information, such individual should contact Initiate Systems’ Chief Privacy Officer at the address provided below or by sending an e-mail to us at chiefprivacyofficer@initiatesystems.com. Written communication should be addressed as follows:
Chief Privacy Officer
EU Safe Harbor Opt-Out
Initiate Systems, Inc.
200 West Madison, Suite 2300
Chicago, Illinois 60606
Prior to making any alterations in its information, Initiate Systems will require that individuals confirm their identity.
Data Integrity
Initiate Systems will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Initiate Systems will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
Onward Transfer
Initiate Systems complies with the notice and choice principles as described above for all data which is disclosed or transferred to a third party.
Initiate Systems will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Initiate Systems will require that its agents either: (i) subscribe to the EU Safe Harbor Principles, the EU Data Protection Directive or another adequacy finding; or (ii) enter into a written agreement with Initiate Systems requiring them to provide the same level of protection as Initiate Systems.
Security
Initiate Systems will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Initiate Systems limits access to personal information and data to those persons in Initiate Systems’ organization, or agents of Initiate Systems, that have a specific business purpose for maintaining and processing such information and data. Individuals who have been granted access to personal information are aware of their responsibilities to protect the security, confidentiality and integrity of that information.
Any security compromises or potential security compromises and any inquiries concerning security should be reported to the Initiate Systems’ Chief Privacy Officer. Contact information for the Chief Privacy Officer is provided above.
Access
Upon request, Initiate Systems will grant individuals reasonable access to personal information that it holds about them. In addition, Initiate Systems will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Initiate Systems agrees to process all reasonable requests for access within a reasonable time period, but reserves the right to deny access or limit access in cases where the burden or cost of providing access would be disproportionate to the risks to the individual's privacy or in the case of a vexatious or fraudulent request. Any employee of Initiate Systems that desires to review or update their personal information can do so by contacting their human resources representative.
Enforcement
Individuals who wish to file a complaint or who take issue with Initiate Systems' EU Safe Harbor policies should direct such communication to Initiate Systems' Chief Privacy Officer via e-mail or written communication at the address provided above. Initiate Systems' Chief Privacy Officer will explain the process to be followed when filing a complaint. Filing a complaint in English will expedite the process. Initiate Systems 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 Initiate Systems and the complainant, Initiate Systems has 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.
Initiate Systems is also subject to the jurisdiction of the US Federal Trade Commission. The Federal Trade Commission may be contacted at the following address:
Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580
Email: consumerline@ftc.gov
www.ftc.gov
Your Privacy Choices
When you submit an inquiry via the "Contact Us" pages of the Site, you may receive materials regarding Initiate Systems' products and services by mail or e-mail. You may opt out of receiving these materials by visiting this web page Contact Us or contacting us by e-mail at info@initiatesystems.com.
Updating Your Personal Information
With respect to Web Site Data, you can always contact us in order to: (i) delete your personal information from our systems, (ii) update the personal information that you have provided to us, and (iii) change your preferences with respect to receiving information regarding Initiate Systems' products and services.
Questions
If you have questions or issues regarding this Privacy Policy, the practices of Initiate Systems, or your dealings with Initiate Systems, please contact us at:
Initiate Systems Systems, Inc.
200 West Madison, Suite 2300
Chicago, Illinois 60606
Phone: 1 312 759 5030
E-mail: info@initiatesystems.com