“Personal Information” or “Information” means information that (1) is recorded in any form; (2) is about, or pertains to a specific individual; and (3) can be linked to that individual.
The Personal Information the Company receives comes from use of our web site by individuals and use of our services by employees of a customer company or by administrators on behalf of such employees of a customer company. The Company uses this Personal Information solely to directly contact individuals who express interest in receiving our services or to provide such services. The Company does not sell any Personal Information to any third parties.
Company shall inform an individual providing his or her Personal Information directly 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. If the individual is providing his or her Personal Information directly, then 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.
If in connection with providing its services, the Company receives Personal Information indirectly through an administrator employee, and not the individual with respect to which the Personal Information is regarding, then the administrator employee has received the express or implied consent of the applicable employee with whose Personal Information is being provided.
The Company will offer individuals providing their Personal Information directly and administrator employees the opportunity to choose (opt out) whether the Personal Information provided by them 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.
By using the Company’s services and providing Personal Information to the Company through such use, individuals or administrators on behalf of those individuals have opted to authorize the Company to use the Personal Information for the purpose it was intended but for no other purpose.
The Company may provide Personal Information to third parties performing services on the Company’s behalf for the benefit of such individuals whose Personal Information is being disclosed provided that such third parties have agreed in writing with Company that they will provide at least the same level of privacy protection as is required by the Principles. Other than as permitted in the prior sentence, prior to disclosing Personal Information for any other purpose, Company shall notify the individual or company administrator employee 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.
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.
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.
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
4683 Chabot Drive, Suite 260
Pleasanton, CA 94588
Effective date: March 20, 2011