This Safe Harbor Notice (the “Notice”) sets forth the privacy principles followed by TinderBox in connection with the transfer and protection of “personal information” received from the European Union (“EU”) or Switzerland.
TinderBox 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. To learn more about the Safe Harbor program, please visit http://www.export.gov/safeharbor.
About the Safe Harbor
The “Safe Harbor” program was jointly established in June 2000 by the United State Department of Commerce and the European Commission, as a method for transferring personal information from the EU to companies in the Unites States. Certified companies represent that they are upholding privacy standards for personal information received from the EU that have been jointly accepted by the EU Commission and the US Department of Commerce. These standard exceed current US privacy standards. TinderBox upholds this commitment.
“Personal Information” means information that can directly or indirectly lead to the identification of a living person, such as an individual’s name, address, e-mail, telephone number, license number, medical identification number, photograph, or other identifying characteristic. The identification can occur by reference to one or more factors specific to the individual’s physical, physiological, mental, economic, cultural or social identity. Personal information does not include information that has been anonymized, encoded or otherwise stripped of its identifiers, or information that is publicly available, unless combined with other non-public personal information.
This Notice governs personal information transferred from countries in the EU or Switzerland (which has adopted substantially similar privacy laws to those of the EU), to the United States on behalf of TinderBox. It applies to personal information in electronic and off-line formats.
Safe Harbor Privacy Principles
The following privacy principles apply to the transfer, collection, use or disclosure of personal information from the EU by TinderBox.
Consistent with the Safe Harbor requirements, TinderBox may not be in a position to furnish notice in certain limited situation. Specifically, notice is not required where the processing of EU personal information is necessary to respond to a government inquiry; is required by applicable laws, court orders or government regulations; or is necessary to protect TinderBox’s legal interests and providing notice would interfere with those interests.
TinderBox will not process personal information about EU individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the EU individual unless the individual affirmatively and explicitly consents (“opt-in”) to the processing, or unless an exception applies.
TinderBox seeks to ensure that any personal information held about EU individuals is accurate, complete, current and otherwise reliable in relation to the purposes for which the information was obtained. TinderBox collects personal information that is adequate, relevant and not excessive for the purposes for which it is to be processed. EU individuals have a responsibility to assist TinderBox in maintaining accurate, complete and current personal information about them.
TinderBox will not transfer personal information about EU individuals to 3rd parties unless the 3rd party (a) has provided satisfactory assurance to TinderBox that it will protect the information consistently with this Notice; or (b) is located in the EU or a country considered “adequate” for privacy by the EU Commission, and therefore is required to comply with the EU data protection laws or substantially equivalent privacy laws; or (c) the 3rd party has also certified to the Safe Harbor, and is accordingly independently responsible for complying with the Safe Harbor requirements.
Where TinderBox has knowledge that a 3rd party to whom it has provided EU personal information is processing that information in a manner contrary to this Notice or the Safe Harbor requirements, TinderBox will take reasonable steps to prevent or stop the processing.
Upon written request to TinderBox, TinderBox will provide EU individuals with reasonable access to their personal information. TinderBox will also take reasonable steps to allow EU individuals to review their information for the purposes of correction their information. There are certain limitations to the Access and Correction rights, as set forth in the US Department of Commerce’s Safe Harbor website. [http://www.export.gov/safeharbor/]
TinderBox takes reasonable precautions to protect EU personal information in its possession from loss, misuse, unauthorized access, disclosure, alteration and destruction.
TinderBox has established internal mechanisms to verify its ongoing adherence to this Notice. TinderBox also encourages individuals covered by this Notice to raise any concerns about our processing of their personal information by contacting TinderBox at the address below or by contacting their local privacy officer. TinderBox will seek to resolve any concerns.
Adherence to these privacy principles may be limited to the extent required to meet a legal, governmental, national security or public interest obligation.
Questions or comments about this Notice should be directed to:
5255 Winthrop Ave
Indianapolis, IN 46220