By managing and processing client's marketing database in compliance with the Safe Harbor Principles, 89 Degrees Inc. (‘The Company') provides professional services to support its clients' consumer marketing communications on behalf of and in consistency with its Client's direction.
The Company 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. The Company 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 89 Degrees' certification, please visit http://www.export.gov/safeharbor/
III. Personal Information
This Policy applies to all Personal Information received by the Company in any format and from any sources including electronic, paper or verbal.
The Company collects, receives, and processes Personal Information from current and former employees and their respective family members, as well as applicants for employment, customers, prospective clients, customers' end users (including, but not limited to customers' employees and customers).
The Company also collects, receives, and process Personal Information such as names of the Company's customers on behalf of its Client and in consistency with its Client's direction. The Company does not receive and store the Client's customer's personal names in combination with confidential data such as a social security number, a driver's license number, or a credit or debit card number.
All the information collected by the Company is the Company property. All the Client data is Client's property. All the Company data and Client data are guarded with security and integrity as proprietary.
All Personal Information collected or received by the Company will be used for legitimate business purposes in consistency with and in compliance with this Policy. The Company will not sell or share any of the Personal Information with Third Parties in ways different than what is disclosed in this Policy.
IV. Privacy Principles
The privacy principles in this Policy are developed in consistency with and in compliance with the Safe Harbor Principles by meeting the requirements of the seven safe harbor principles. Where a conflict exists between the provisions of this policy and the Safe Harbor Principles, the Safe Harbor Principles will govern.
Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the Company Privacy Officer. The Company 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 the Company and the complainant, the Company has agreed to participate in the dispute resolution procedures of the American Arbitration Association ("AAA") in accordance with its applicable commercial rules as well as the Safe Harbor Principles; provided further that any arbitrator shall be either an attorney or retired judge having significant and recognized experience with, and knowledge of, privacy issues and information technology. In addition, the exclusive location for such arbitration shall be Boston, MA (USA). All decisions of the arbitration panel shall be final and binding on the parties, which waive any right to further appeal the arbitration award, to the extent an appeal may be lawfully waived. The Company is also subject to the jurisdiction of the US Federal Trade Commission. The Federal Trade Commission may be contacted at the following address:
VI. Effective Date and Changes
The practices described in this Policy are the current Personal Information protection policies as of May 31, 2010. It shall be posted on the Company website at www.89degrees.com. The Company 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.
V. Privacy Officer and Contact Information
The Company has information security infrastructure, procedures and policies, and best practices in place to provide secured data privacy protection for individuals and businesses as well.
The Company educates, trains, and mandates its employees' awareness most likely to be in possession of or accessing Personal Information concerning compliance with this Policy and to assure compliance.
David Simcik, The Company's Director of Consulting and Campaign Services, is designated as the Privacy Officer responsible for the Company's compliance with and enforcement of this Policy and The Company's data security practices.
The Privacy Officer is available to any of its valued employees, clients, customers, vendors, business partners or others who may have questions concerning this Policy or data security practices. Questions or complaints regarding this Policy and any privacy-related issue should be submitted by mail or email to the Privacy Officer, as indicated below:
25 Mall Road, Suite 610
Burlington, MA 01803