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The Safe Harbor Policy is meant to be posted on your web site if you are collecting personal information from people residing in countries of the European Union (EU). The European Commission's Directive on Data Protection (October, 1998) prohibits the transfer of Personal Data to non-European Union nations that do not meet the European adequacy standard for privacy protection. In order to bridge these different privacy approaches and provide a streamlined means for U.S. organizations to comply with the Directive, the U.S. Department of Commerce, in consultation with the European Commission, developed a "Safe Harbor" framework. The Safe Harbor approved by the EU in July of 2000 is a way for U.S. companies to avoid experiencing difficulties with their dealings with the EU or potentially facing prosecution by EU authorities under European privacy laws.
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Related documents may be used in conjunction with this document depending on your situation. Many related documents are intended for use as part of a contract management system.

Related Documents:
EU Safe Harbor Policy Template
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How to write my EU Safe Harbor Policy Template document

Introduction to Safe Harbor The European Commissions Directive on Data Protection October prohibits the transfer of Personal Data to non European Union nations that do not meet the European adequacy standard for privacy protection. In order to bridge these different privacy approaches and provide streamlined means for U. S. organizations to comply with the Directive the U. S. Department of Commerce in consultation with the European Commission developed Safe Harbor framework. The Safe Harbor approved by the EU in July of is way for U. S. companies to avoid experiencing difficulties with their dealings with the EU or potentially facing prosecution by EU authorities under European privacy laws. company name Safe Harbor Privacy Policy company name hereinafter referred to as Company values individual privacy and respects the privacy of its customers clients employees vendors partners and others. company name endeavors to gather use and disclose Personal Data in manner consistent with the laws of the countries in which it does business and upholds the strictest ethical standards in its practice of business. This Safe Harbor Privacy Policy the Policy sets forth the privacy principles that company name follows with respect to private and Personal Data transferred from the European Union EU to the United States. Compliance with Safe Harbor The United States Department of Commerce and the European Commission have agreed on set of data protection principles and frequently asked questions the Safe Harbor Principles to enable U. S. companies to satisfy the adequacy standard requirement under EU law that protection be given to Personal Data transferred from the EU to the United States. Consistent with its commitment to protect personal privacy company name adheres to the following Safe Harbor Principles. SCOPE The scope of this Safe Harbor Privacy Policy applies to any Personal Data received by company name in the United States from the EU in any format including verbal written electronic or printed paper; or transferred from one format to another and stored by Company or Company Agent. DEFINITIONS

For purposes of this Safe Harbor Policy the following definitions shall apply. Company means company name its predecessors successors subsidiaries divisions and groups. Agent means any third party that collects or processes or otherwise uses Personal Data or Personal Sensitive Data solely on behalf or under the instruction of company name. Personal Data means any information or set of information that identifies or can reasonably be used to identify an individual. Personal Data does not include data that is encoded encrypted or made anonymous in part or in whole or publicly available information that has not been combined with non public Personal Data. Sensitive Personal Data means Personal Data that reveals race ethnic origin political opinions religious or philosophical beliefs or trade union membership or that concerns an individuals health or sex life. Information is treated as sensitive Personal Data when it is received from user or third party that treats and identifies it as sensitive.

The following privacy principles apply to the collection use and disclosure of Personal Data by company name activities. The Information Collected and How it is Used. Aggregate and Statistical Data company name collects certain aggregate data for general statistical information every time web site is visited. This information is collected through the server web logs and may consist of. Dates and times of visits to our web site ; the IP addresses of visitors to our web site ; the operating system and browser version of the computers of visitors to our web site s. This data is not used individually to identify users of our web site s. This data is used to analyze system performance usage peak usage and usage trends. Cookies company names web site employs the use of cookies. Cookies are small data files text that are transferred from standard web server to users browser. Cookies contain information that can be read by the Web server for record keeping purposes. Use of cookies is standard practice on the Internet and can improve the service web site provides. The information stored in cookies is not used to personally identify an individual and does not contain Personal or Sensitive Personal data. Cookies may be rejected if users browser is set to reject or deny cookies; if user has third party program installed that interferes or prevents cookies i. e. certain firewalls anti virus or anti spyware programs or notifies the user whenever cookie is sent to the users computer. Cookies sent by company namethat are rejected may limit access to company names web sites or the web site may no longer function as intended or be accessible to the user. Personal Data Submitted by Users All personally identifiable information received by company name is voluntarily submitted by users or submitted on the users behalf by our client company. This information is only used by the specific client web site for the intended purposes of that web site. Web sites are designed to fulfill specific business needs and all Personal Data that is voluntarily collected by company name is to provide services or is used to improve the service that the company name web site provide.

company name Safe Harbor Privacy Principals The privacy principles in this Policy are based on the Safe Harbor Principles. Notice. Where company name collects Personal Data directly from individuals in the EU it will inform them about the type of Personal Data collected the purposes for which it collects and uses the Personal Data and the types of non agent third parties to which company name discloses or may disclose that information and the choices and means if any company name offers individuals for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to company name or as soon as practicable thereafter and in any event before company name uses or discloses the information for purpose other than that for which it was originally collected. Where company name receives Personal Data from their subsidiaries affiliates or other entities in the EU they 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 Data relates. Choice.

company name will offer individuals the opportunity to choose opt out whether their Personal Data is to be disclosed to non agent third party or to be used for purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For sensitive Personal Data company name will give individuals the opportunity to affirmatively and explicitly consent opt in to the disclosure of the information to non agent third party or the use of the information for purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. company name will provide individuals with reasonable mechanisms to exercise their choices. Integrity of Data. company name will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. company name will take reasonable steps to ensure that Personal Data is relevant to its intended use accurate complete and current. Transfers to Agents. On occasion company name will provide information stored on our web sites to agents for the purpose of integrating with that agents product or service offerings. This integration is performed at the request of our client company to further their business needs and to provide services or is used to improve the service that company names web site provide. Data that is shared may include name email address employee ID and unique system identifier. Contractual agreements are made between the agent to whom the data is being transferred and our client for whom the data is being stored. company names agents are assumed to hold similar privacy standards as company name. When company name becomes aware that an agent is using or disclosing Personal Data or Personal Sensitive in manner that is improper or that is contrary to this Safe Harbor Policy company name will take all reasonable measures to stop or prevent the use or disclosure of such data. Access and Correction. Information that is stored about the users of our web site is accessible and editable directly from within our web site s. company name permits users to edit correct or delete any information that they feel is inaccurate or incomplete. Should an individual not be able to access or correct this information please contact the Safe Harbor Office listed at the bottom of this Safe Harbor Policy to obtain information about how to access and edit their Personal Data or Personal Sensitive data within the site. In the event that the individual still cannot access or correct their Personal Data they may contact company name through one of the communication methods described below.

Security of Information. company name is committed to your privacy and to ensure the security and safety of your information. company name will take all reasonable precautions to protect all Personal and Sensitive Personal data in its possession from unauthorized access loss or misuse. This includes but is not limited to the use of 128 bit encryption technology regularly scheduled backups of data secured storage of all Sensitive Personal information and access limitations and restrictions to the servers and computers that contain such data. Enforcement of Policy. company name will conduct periodic audits of its relevant privacy practices to verify its compliance and adherence to this Safe Harbor Policy. Any employee or agent that company name determines is in violation of this policy will be subject to disciplinary action including but not limited to. fines sanctions criminal prosecution revocation of contract and or termination of employment. Resolution of Disputes.

Any questions or concerns regarding the use or disclosure of Personal Data should be directed to company names Safe Harbor Officer at the address given below. company name will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the principles contained in this Policy. For complaints that cannot be resolved between company name and the complainant company name 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. Limitations on Application. Adherence by company name to these Safe Harbor Principles may be limited to the extent required to respond to legal or ethical obligation; and to the extent expressly permitted by an applicable law rule or regulation. Web sites created by company name may contain links to other Web sites. Please be aware that company name is not responsible for the privacy practices of these web sites. company name does not endorse them or make any representations about them or any information services products or materials found on them. Users are strongly encouraged to read the privacy policies of any third party sites accessed through links. Contact Information Questions comments or concerns regarding the Safe Harbor Policy may be directed to mail address or to the following Safe Harbor Officer or Company representative by mail. company name address address city state or province zip or postal code Changes to this Safe Harbor Agreement

The practices described in this Safe Harbor Policy are current as of current date. company name reserves the right to modify or amend this Policy at any time consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning such amendments. This Policy may be changed periodically in accordance with the requirements of the Safe Harbor Principles. Changes to the Safe Harbor policy will be posted on our web site or users of our web site may be notified via email. Effective Date. current date

Writing the Interactive Service Disclaimer Policy document (alternate or related contract document)

This policy is intended to be used as starting services policy template for online use. Edit as needed for each specific web site and integrate the text into the web site HTML code and reformat as needed. company name DISCLAIMER FOR INTERACTIVE SERVICES company name maintains the interactive portion of their Web Site web site domain URL as service free of charge. By using any interactive services provided herein you are agreeing to comply with and be bound by the terms conditions and notices relating to its use. 1. As condition of your use of this Web Site and the interactive services contained therein you represent and warrant to company name that you will not use this Web Site for any purpose that is unlawful or prohibited by these terms conditions and notices. 2. This Web Site contains one or more of the following interactive services. bulletin boards chat areas news groups forums social networks communities and or other message or communication facilities. You agree to use such services only to send and receive messages and material that are proper and related to the particular service area group forum community or other message or communication facility. In addition to any other terms or conditions of use of any bulletin board services chat areas news groups forums social networks communities and or other message or communication facilities you agree that when using one you will not. Publish post upload distribute or disseminate any inappropriate profane derogatory defamatory infringing improper obscene indecent or unlawful topic name material or information.

Upload files that contain software or other material protected by intellectual property laws or by rights of privacy of publicity unless you own or control such rights or have received all necessary consents. Upload files that contain viruses corrupted files or any other similar software or programs that may damage the operation of anothers computer. Advertise any goods or services for any commercial purpose. Offer to sell any goods or services for any commercial purpose. Conduct or forward chain letters or pyramid schemes. Download for distribution in any manner any file posted by another user of forum that you know or reasonably should know cannot be legally distributed in such manner. Defame abuse harass stalk threaten or otherwise violate the legal rights such as rights of privacy and publicity of others. Falsify or delete any author attributions legal or other proper notices proprietary designations labels of the origin source of software or other material contained in file that is uploaded.

Restrict or inhibit any other user from using and enjoying any of the bulletin board services chat areas news groups forums communities and or other message or communication facilities. 3. company name has no obligation to monitor the bulletin board services chat areas news groups forums social networks communities and or other message or communication facilities. However company name reserves the right at all times to disclose any information deemed by company name necessary to satisfy any applicable law regulation legal process or governmental request. company name reserves the right at all times to edit refuse to post or remove any information or materials in whole or in part. 4. You acknowledge that communications to or with bulletin board services chat areas news groups forums social networks communities and or other message or communication facilities are not private communications therefore others may read your communications without your knowledge. You should always use caution when providing any personal information about yourself or your children. company name does not control or endorse the content messages or information found in any bulletin board services chat areas news groups forums social networks communities and or other message or communication facilities and specifically disclaims any liability with regard to same and any actions resulting from your participation. To the extent that there are moderators forum managers or hosts none are authorized company name spokespersons and their views do not necessarily reflect those of company name. 5. The information products and services included on this Web Site may include inaccuracies or typographical errors. Changes are periodically added to the information herein. company name may make improvements and or changes in this Web Site at any time. Advice received via this Web Site should not be relied upon for personal legal or financial decisions and you should consult an appropriate professional for specific advice tailored to your situation. 6. company name makes no representations about the suitability reliability timeliness and accuracy of the information products and services contained on this Web Site for any purpose. All such information products and services are provided as is without warranty of any kind.

7. company name hereby disclaims all warranties and conditions with regard to the information products discounts coupons offers and services whether explicitly implied or not contained on this Web Site including all implied warranties and conditions of merchantability fitness for particular purpose title and non infringement. 8. In no event shall company name be liable for any direct indirect punitive incidental special consequential damages or any damages whatsoever including without limitation damages concerning the use or non use of any products offers discounts or services that result in the loss of use data or profits arising out of or in any way connected with. the use or performance of this Web Site or its products the delay or inability to use this Web Site or its products the provision of or failure to provide services discount or availability any information software products services and related graphics obtained through this Web Site or otherwise arising out of the use of this Web Site whether based on contract tort strict liability or otherwise even if company name has been advised of the possibility of damages. 9. Due to the fact that certain jurisdictions do not permit or recognize an exclusion or limitation of liability for consequential or incidental damages the above limitation may not apply to you. If you are dissatisfied with any portion of this Web Site or with any of these terms of use your sole and exclusive remedy is to discontinue using this Web Site. 10. company name reserves the right in its sole discretion to deny any user access to this Web Site any interactive service herein or any portion of this Web Site without notice and also reserves the right to change the terms conditions and notices under which this Web Site is offered. 11. This Agreement contains the entire agreement between the parties relating to the subject matter hereof and supersedes any and all prior agreements or understandings written or oral between the parties related to the subject matter hereof. No modification of this Agreement shall be valid unless made in writing and signed by both of the parties hereto.

12. This Agreement shall be governed by and construed in accordance with the laws of the State of state or province. Exclusive jurisdiction and venue shall be in the county County state or province Superior Court. Binding Effect. This Agreement shall be binding upon all who use company names services property and other assets mentioned in this agreement with respect to this Web Site and associated content and it supersedes all prior or contemporaneous communications and proposals whether electronic oral or written with respect to this Web Site. printed version of this agreement and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to this agreement to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form. Fictitious names of companies products people characters and or data mentioned herein are not intended to represent any real individual company product or event. Any rights not expressly granted herein are reserved.

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