Safe Harbor Policy
Ipro Tech, LLC (Ipro) recognizes that privacy is very important to our customers and employees, and therefore strives to protect the personal information it collects and handles. This Policy sets forth the privacy principles that Ipro follows with respect to transfers of personal information from the European Union (EU) to the U.S.
Ipro 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. Ipro 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 Ipro’s integrated certification, please visit www.export.gov/safeharbor.
This Policy applies to all personal information received by Ipro U.S. from the EU. It may pertain to third party individuals in connection with Ipro U.S. providing technical and solutions support to EU-based clients, or clients in possession or control of personal information in the EU, although Ipro’s U.S. personnel would in most instances not have direct contact with those third party individuals about whom such information pertains.
The following definitions shall apply throughout this Policy:
“Agent” means any third party that uses personal information provided to Ipro to perform tasks on behalf of and under the instructions of Ipro.
“Ipro” means Ipro Tech, LLC
“Ipro U.S.” means Ipro’s U.S.-based business.
“EU” means the European Union, including its member states.
“Personal information” means any information or set of information that identifies an individual, or could be used by or on behalf of Ipro to identify an individual.
“Policy” means this Safe Harbor Policy.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual’s health or sex life. In addition, Ipro will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
“U.S.” means the United States and its territories.
The privacy principles in this Policy are based on the Safe Harbor Privacy Principles.
When Ipro collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses their personal information, the types of non-agent third parties, if any, to which Ipro discloses that information, and the choices and means, if any, that Ipro 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 Ipro, or as soon as practicable thereafter, and in any event before Ipro uses the information for a purpose other than that for which it was originally collected.
Ipro will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party (unless allowed or required by contract), 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, Ipro will give individuals the opportunity to affirmatively and explicitly consent (e.g., through an opt-in) 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.
Ipro will provide individuals with reasonable methods to exercise their choices.
Ipro will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. If Ipro has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Ipro will take reasonable steps to prevent or stop the use or disclosure.
Ipro will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Ipro will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Ipro will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
Upon request, Ipro will grant individuals reasonable access to personal information that it holds about them, and Ipro will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
Ipro will conduct compliance reviews of its relevant privacy practices to verify adherence to this Policy. Any employee that Ipro determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
Any questions or concerns regarding the use or disclosure of personal information should be directed to Ipro at the email and mailing addresses given below. Ipro 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 Ipro and the complainant, Ipro 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.
Questions or comments regarding this policy should be submitted to:
Ipro Tech, LLC 6811 E. Mayo Blvd, Suite 350 Phoenix, AZ 85054 firstname.lastname@example.org
Please include your name, address, and phone number or email in all communications and clearly state the nature of your request.
Changes to this Policy
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning such changes.
Limitation on Application of Principles
Adherence by Ipro to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation, and (b) to the extent permitted by applicable law.
Effective Date: January 31, 2014