Safe Harbor Policy Statement
Last Updated on November 23, 2011
Aasonn and its subsidiaries and affiliates (hereinafter, collectively "Aasonn" or the "Company") acknowledges the European Union and Switzerland's standard for personal data protection. Aasonn is committed to protecting the privacy of our employees, customers, business partners and others. Not only does Aasonn strive 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 has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy Statement (the "Privacy Policy") sets forth the privacy principles that Aasonn follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.
Aasonn will adhere to the United States Department of Commerce Safe Harbor Principles and will self-certify to the United States Department of Commerce compliance with the Safe Harbor Principles. This Policy applies to all data transmissions from Aasonn operations in EU countries to the United States. This includes transmission of data over phone lines, computer lines, and in hard copy, and includes such material as payroll records, telephone records, performance evaluations, and any material that identifies a particular individual employee.
Aasonn complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Aasonn has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Aasonn's certification, please visit http://www.export.gov/safeharbor/.
This Privacy Policy describes Aasonn's practices for implementing the Safe Harbor Principles, and applies to all personal information received by the Company in the U.S. from the EEA and from Switzerland, in any format. For the purpose of this Policy, "personal information", means any information or set of information that identifies or could be used by or on behalf of Aasonn 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 information.
Personal information may be disclosed to judicial or other government agencies subject to warrants, subpoenas, or other governmental orders.
Pursuant to EU guidelines on privacy, Aasonn does not intentionally collect information from individuals who are 13 years of age or under and if notified will destroy that information immediately.
In the event of a bankruptcy or merger, all personal information will be handled according to the following Guidelines.
Guidelines
Aasonn has adopted the seven Safe Harbor principles of notice, choice, onward transfer (transfer to third parties), access, security, data integrity and enforcement with respect to personal information to be transferred to Aasonn Operations in the U.S. from the EEA and from Switzerland.
- Notice - Aasonn will notify person's in the EU about the purposes for which personal data will be collected and used. Information will be provided on how individuals can contact Aasonn with inquiries or complaints regarding personal data. Aasonn will give notice to people regarding third parties to which it discloses the information, and restrictions that limit the information's use and disclosure.
- Choice - Prior to releasing personal data to a third party, Aasonn will give an individual employee the opportunity to choose whether their personal data is disclosed to that third party or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by that individual. For sensitive data, an affirmative choice will be given to the individual if the personal data is to be disclosed to a third party or used for a purpose other than its original purpose or the purposes authorized subsequently by the individual.
- Transfers to third parties - Aasonn 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. Where Aasonn has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Aasonn will take reasonable steps to prevent or stop the use or disclosure.
- Access - Person's covered under this policy will have access to personnel information about them that Aasonn holds and will be able to correct, amend or delete information if it is inaccurate (the exception is when the burden or expense of providing access would be disproportionate to the risks of the individual privacy in the case in question or the rights of persons other than the individual would be violated.)
- Retention - Aasonn will retain personal information for a period that suits the business purpose of maintaining that information. If such personal information is for the purposes of our consulting work with a customer, that information will be destroyed immediately after any business need for that information ceases to exist. In on case will personal information be kept for more than 3 years.
- Security - Aasonn will take reasonable precautions to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
- Data Integrity - Personal data kept by Aasonn will be relevant for the purposes for which it is to be used. Aasonn will take reasonable steps to ensure that the data is reliable and that it is applied to its intended use. Aasonn will also ensure that the information is accurate, complete and correct.
- Enforcement - To ensure compliance with these Safe Harbor Principles, Aasonn will: 1) Commit to cooperate with the Data Protection Authorities (DPAs) of the EU countries and the Swiss FDPIC (for information received from Switzerland) in the investigation and resolution of complaints and will comply with any advice given by DPAs; 2) Employ a procedure for verifying that the commitment the company has made to adhere to the Safe Harbor Principles has been implemented; and 3) Remedy issues arising out of any failure to comply with the Principles. Aasonn acknowledges that its failure to provide an annual self-certification to the Department of Commerce will remove it from its list of participants and the transfers of information will not be allowed unless Aasonn otherwise complies with the EU Data Protection Directive and Swiss FDPIC.
Aasonn executive management will be the internal mechanism for ensuring compliance with the Safe Harbor Principles and facilitating the independent recourse mechanism referenced in the Enforcement provision of this Policy.
Dispute Resolution
All disputes arising out of or in connection of the handling of personal information by Aasonn will be handled swiftly by Aasonn executive management. Employees located in the EEA should forward any complaints or disputes regarding personal data protection to their local HR representatives. All other questions or concerns regarding the use or disclosure of personal information should be directed to Aasonn at the address given below in the Responsibilities and Contact Information section of this Privacy Policy.
Aasonn 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 Aasonn and the individual complainant, Aasonn commits to cooperate with the European Data Protection Authorities (for personal information received from the EEA) and the Swiss FDPIC (for information received from Switzerland) and comply with any advice given by them.
Definitions
European Union - The European Union ("EU") consists of 27 member countries: Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, France, Finland, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and United Kingdom.
Personal Data - (for the purposes of this policy) - Any personal information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by a reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.
Self-Certification to the Department of Commerce - Aasonn will certify to the U.S. Department of Commerce that it will abide by the Safe Harbor Principles. Aasonn must also state annually in its published privacy policy statement that it adheres to the Safe Harbor.
Sensitive Data - Sensitive data is data that pertains to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, income records, health, sexual orientation or alleged commission of any offense. This data may not be transferred unless an individual gives explicit consent.
Agent - For the purposes of this Policy, "agent" means any third party that collects or uses personal information under the instructions of, and solely for Aasonn or to which Aasonn discloses personal information for use on Aasonn's behalf.
Responsibilities and Contact Information
Questions regarding the transmission of personal data from the European Union (EU) to the United States or any other non-EU location, or any further transmission of the personal data once received in the United States, should be referred to the CEO. In implementing this policy, Aasonn agrees to annually self-certify to the U.S. Department of Commerce that it will adhere to the Safe Harbor Principles.
If by Postal Service Delivery:
Aasonn
Attn: CEO
184 Shuman Blvd, Suite 530
Park Lake Center
Naperville, IL 60563 USA
+1 (630) 718-1562
If by facsimile:
+1 (630) 718-1564
If my Email:
info@aasonn.com
General Provisions of our Online Privacy Policy
Aasonn knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and responsibly. This policy notice describes the way in which we honor that trust and how we treat your privacy. By visiting Aasonn.com, you are accepting the practices described in this Privacy Policy.
What Personal Information About Website Visitors Does Aasonn Gather?
The information we learn from our Website Visitors helps us personalize and systematically improve your experience at Aasonn.com. Here are the types of information we gather.
Information You Give Us: We receive and store any information you enter on our Web site or give us in any other way. You can choose not to provide certain information, but then you might not be able to take advantage of many of our site's features. We use the information that you provide to us for such purposes as responding to your requests, improving future visits for you, adding new features to our site, and communicating with you.
Automatic Information: We receive and store various types of information whenever you visit us. For example, like many Web sites, we may use "cookies", and we obtain certain types of information when your Web browser accesses Aasonn.com. A number of companies offer utilities designed to help you visit Web sites anonymously. Although we will not be able to provide you with a personalized experience at Aasonn.com if we cannot recognize you, we want you to be aware that these tools exist.
E-mail Communications: From time to time, we will send you notices about events, our sponsor's promotions, or other technology or human resources news. If you do not want to receive e-mail or other mail from us, please let us know.
What About Cookies?
Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your Web browser to enable our systems to recognize your browser and for keeping track of your page visits.
The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, cookies allow you to take full advantage of some of Aasonn.com's site features, and we recommend that you leave them turned on.
Does Aasonn.com Share the Information It Receives?
Information about our Website Visitors is an important part of our business, and we are not in the business of selling it to others. We share customer information only as described below and with subsidiaries that Aasonn, LLC controls that either are subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice.
How Secure Is Information About Me?
We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software when appropriate or deemed necessary. SSL encrypts information you input for the purposes of our online services. If you are using a personalized feature of our website, it is important to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.
Any financial information collected will be transmitted in an encrypted fashion and kept as securely as current technology allows. Aasonn will take every measure available to the company to safeguard your personal financial information.
Which Information Can I Access?
Aasonn.com gives you access to a broad range of information about your account and your interactions with us for the limited purpose of viewing and, in certain cases, updating that information if you have signed up for a personalized service on our website.
What Choices Do I Have?
As discussed above, you can always choose not to provide information, even though it might be needed to register for an event. If you do not want to receive e-mail or other mail from us, please adjust your User Preferences.
Terms of Use, Notices, and Revisions
If you choose to visit Aasonn.com, your visit and any dispute over privacy is subject to this Notice and our Terms of Use Agreement, including limitations on damages, arbitration of disputes, and application of the law of the state of Illinois. If you have any concern about privacy at Aasonn.com, please contact us with a thorough description or your concern, and we will try to resolve it.
Our business changes constantly, and our Privacy Notice and the Terms of Use will change also. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our Web site frequently to see recent changes. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account if you've subscribed to a personalized feature. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected Website Visitors.
Information You Give Us
You provide most such information when you search, post, participate in a forum, or communicate with our customer service. For example, you provide information when you search for a service or document; place a customer service inquiry through Aasonn.com; provide information in Your Account (and you might have more than one if you have used more than one e-mail address when using our website); communicate with us by phone, e-mail, or otherwise; complete a questionnaire; use our register for events; participate in forums; or request information. As a result of those actions, you might supply us with such information as your name, address, and phone numbers; people to whom you've been to our sponsor's events, including addresses and phone number; content of reviews and e-mails to us; and possibly personal descriptions;.
Automatic Information
Examples of the information we collect and analyze include the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information such as browser type and version, operating system, and platform; which we sometimes aggregate with similar information from other Website Visitors to create features such as Top Events, and Seminar Suggestions based on your use of our website; the full Uniform Resource Locator (URL) clickstream to, through, and from our Web site, including date and time; cookie number; services you viewed or searched for; and the phone number you used to call our office when this occurs. During some visits we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
