1010data Global Telecom Solutions LLC and its affiliated companies (“1010data”, “we”, “us”, or “our”) recognize that privacy is very important to our customers. We pledge to protect the security and privacy of any personal information that customers provide to us. This includes customer names, addresses, telephone numbers, email addresses and any information that can be linked to a specific individual.
U.S. – EU Safe Harbor / U.S.-Swiss Safe Harbor Privacy Statement
1010data strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business. For personal information of employees, consumers, customers, investors, and government officials that 1010data receives from Switzerland, the European Union and by extension the European Economic Area, 1010data has committed to handling such personal information in accordance with the U.S.-EU Safe Harbor Privacy Principles and the US-Swiss Safe Harbor Privacy Principles. 1010data has certified that it adheres to Safe Harbor Privacy Principles (“Principles”) of notice, choice, onward transfer, security, data integrity, access, and enforcement. 1010data’s Safe Harbor certification can be found at https://safeharbor.export.gov/list.aspx. For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s Website at www.export.gov/safeharbor.
If there is any conflict between the language in this Policy and the Principles, the Principles will govern. This Policy outlines our general procedures and practices for implementing the Principles, including the types of information we gather, how we use it, and the choices affected individuals have regarding our use of, and their ability to correct, that information.
Some 1010data customers load personal information into databases on 1010data’s servers and analyze it using 1010data analytic platform. In this capacity, 1010data serves as only a data processor and not a data controller. This personal information remains the property of the respective customers who are data controllers. A customer can permanently delete any personal information at any time.
This Policy applies to any personal information for which 1010data is a data controller. For purposes of this statement, “personal information” means information that: i) is transferred from the EU and/or Switzerland to the United States; ii) is recorded in any form; and iii) can be linked to and used to identify an individual. It does not apply to personal information pertaining to a specific individual from which that individual could not reasonably be identified.
Notice and Choice
To the extent permitted by the Principles, we reserve the right to process personal information in the course of providing professional services to our customers without the knowledge of individuals involved. We do not use personal information or sensitive personal information for any Third-Party Secondary Uses unless the individuals involved affirmatively choose to participate in such Secondary Uses.
1010data does not disclose an individual’s personal information to third parties, except when one or more of the following conditions is true:
1010data takes appropriate physical, technical, and organizational measures to protect all personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction. However, we cannot guarantee the security of personal information transmitted to 1010data via the Internet. 1010data takes significant efforts to prevent, but is not responsible for, unauthorized access by illegal means.
With respect to personal information for which 1010data is a data controller, if any, 1010data processes personal information only in ways compatible with the purpose for which the information was collected or subsequently authorized by the individual. To the extent necessary for such purposes, 1010data will take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.
If an individual becomes aware that personal information we maintain as a data controller about that individual is inaccurate, or if an individual would like to update or review his or her personal information where we are a data controller, the individual may contact us using the contact information below. We will take reasonable steps to permit individuals to correct, amend, or delete personal information that is demonstrated to be inaccurate. The individual will need to provide sufficient identifying personal information to confirm the individual’s identity. We may request additional identifying personal information as a security precaution. In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement.
Enforcement and Dispute Resolution
1010data utilizes the self-assessment approach to assure its compliance with our privacy statement. 1010data periodically (annually, or more often) verifies that the policy is accurate, comprehensive, publicly available, completely implemented, and in conformity with the Principles of US-EU Safe Harbor and US-Swiss Safe Harbor.
1010data 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.
With respect to any complaints relating to this Policy that cannot be resolved through our internal processes, we use the American Arbitration Association’s Safe Harbor dispute process, which can be found at http://www.adr.org. Any employee or contractor who we determine is in violation of our privacy policies will be subject to disciplinary process.
Privacy Statement Changes
Questions or comments regarding this Policy should be submitted to the 1010data Privacy by mail or e-mail as follows:
1010data Global Telecom Solutions LLC
Attn: Greg Munves
750 Third Avenue, 4th Floor
New York, NY 10017
EFFECTIVE DATE: January 1, 2012