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, The Company 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, the Company or to which the Company discloses personal information for use on the Company's behalf.
“Affiliates” means any individual, corporation, company, partnership, trust, limited liability company, association or other business entity which directly or indirectly controls, is controlled by or is under common control of the Company.
"Personal information" means any information or set of information that identifies or is used by or on behalf of the Company 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, the Company 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 the Company 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, the Company 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 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 that for which it was originally collected or discloses information to a non-agent third party.
Where the Company 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.
The Company will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. The company will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. We will only collect and store 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.
The Company will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT: The Company will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that the Company determines intentionally violates this policy will be subject to disciplinary action up to and including termination of employment.
Questions or comments regarding this Policy should be submitted to the Company by mail as follows:
115 Corporate Boulevard
South Plainfield, NJ 07080
8 January, 2016