The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the "U.S.-EU Safe Harbor"). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions 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 (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, Corporate Translations adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”).
The privacy principles in this Policy have been developed based on the Safe Harbor Principles.
NOTICE: Where Corporate Translations 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, the types of non–agent third parties to which Corporate Translations discloses that information, the choices and means, if any, Corporate Translations offers individuals for limiting the use and disclosure of personal information about them, and how to contact Corporate Translations. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Corporate Translations, or as soon as practicable thereafter, and in any event before Corporate Translations uses or discloses the information for a purpose other than that for which it was originally collected.
Where Corporate Translations 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.
CHOICE: Corporate Translations will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, 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, Corporate Translations will give individuals the opportunity to affirmatively and explicitly (opt-in) consent 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.
Corporate Translations will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY: Corporate Translations will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Corporate Translations will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: Corporate Translations 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), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Corporate Translations has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Corporate Translations will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, Corporate Translations will grant individuals reasonable access to personal information that it holds about them. In addition, Corporate Translations will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: Corporate Translations will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT: Corporate Translations will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Corporate Translations determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Corporate Translations Headquarters address given below. Corporate Translations will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between Corporate Translations and the complainant, Corporate Translations has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles. For disputes involving personal information received by Corporate Translations from its customers, Corporate Translations will employ a licensed moderator to mitigate and resolve.
Limitation on Application of Principles
Adherence by Corporate Translations to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
Corporate Translations sees the Internet and the use of other technology as valuable tools to communicate and interact with consumers, employees, healthcare professionals, business partners, and others. Corporate Translations recognizes the importance of maintaining the privacy of information collected online and has standard operating procedures to govern the information collected through the web sites it operates.
Questions or comments regarding this Policy should be submitted to the Corporate Translations Headquarters by mail to:
Corporate Translations, Inc.
77 Hartland Street
East Hartford, CT 06108
EFFECTIVE DATE: July 19, 2012