Safe Harbor Privacy Policy for American River International

 

American River International is committed to protecting the privacy of those companies and individuals who entrust us with their personal information. 

 

American River International adheres to the Safe Harbor Privacy Policy Program.  The Safe Harbor Privacy Policy sets forth the privacy principles that ARI follows with respect to transfers of personal information from the member states of the European Union to the United States.


For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s website at http://www.export.gov/safeharbor

 

Background

 

The EU adopted the Directive on Data Protection ("EU Directive"), which requires EU member states to adopt laws protecting Personal Information collected within their borders. These laws must, among other provisions, restrict the transfer of Personal Information only to countries that have data protection laws deemed "adequate" under standards established in the EU Directive. The U.S. Department of Commerce and the European Commission have agreed on the Principles to enable U.S. Companies to satisfy the requirement under EU law that adequate protection be given to Personal Information transferred from the EU to the U.S.

 

Scope

 

This policy applies to all personal information received by ARI in the US from a member state of the EU in any format including electronic, paper or verbal.  This policy sets certain minimum standards.


Definitions

 

For purposes of this policy, the following definitions shall apply:

 

“Agent” means any third party that uses personal information provided by ARI to perform tasks on behalf of and under the instructions of ARI.

 

“ARI” means American River International, its successors, subsidiaries, divisions and groups in the United States.

 

“Personal information” means any information or set of information that identifies or could be used by ARI to identify an individual.  Personal information does not include information that is encoded or stripped of all personal identifiable information or which is publicly available.

 

 

 

 

 

Privacy Principles

 

The privacy principles in this policy are based on the Safe Harbor Privacy Principles.

 

Notice: Where ARI collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses the information, the types of third parties to which ARI would disclose that information and the means if any for individuals to limit the use and disclosure of their personal information.  Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information and before ARI uses the information for a purpose other than that for which it was originally collected.

 

Where ARI receives personal information from entities in the EU, it will use such information in accordance with the notices provided by such entities.

 

Data Integrity: ARI will use the personal information only in ways that are compatible with the purposes for which the information was collected and subsequently authorized.  ARI will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.

 

Transfers to Agents: ARI does not share individual’s information with agents, contractors or partners.

 

Access and Correction:  Upon request, individuals will be granted reasonable access to their personal information.  In addition, upon request, ARI will take reasonable steps to permit individuals to correct, amend or delete information that is found to be inaccurate or incomplete.

 

Security:  ARI will employ reasonable safeguards to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. 

 

Choice: ARI will offer individuals the opportunity to choose (opt-out) whether their Personal Data 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. In addition, where consent of individuals or their representatives is required by law, contract, or agreement for the collection, use, or disclosure of Personal Information, ARI will request such consent and respect the individual’s choice in such matters.

In certain limited or exceptional circumstances, in accordance with the Safe Harbor Principles, ARI may disclose Personal Information without notice or the consent of the individual. For example, this may occur when ARI is required to disclose information by law or legal process or in the vital interests of the individual, such as when life or health are at stake.

Opt-In Requirement. Except as provided by the Safe Harbor Principles or applicable law, an individual must give affirmative permission (opt in consent) before ARI will disclose Sensitive Data to a third party or use Sensitive Data for a purpose other than those for which it was originally collected or subsequently authorized by the individual.

ARI will provide individuals with reasonable mechanisms to exercise their choices.

 

 

Independent Recourse Mechanism:

 

For complaints that cannot be resolved between ARI and the complainant, ARI 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 Principles.

 

Enforcement and Dispute Resolution: Individuals may contact the Privacy Officer at ARI’s corporate office in Melville, New York, U.S.A. to submit data access requests, register complaints or address any other relevant issues under the Safe Harbor Principles.  It is the responsibility of all employees to act in accordance with the Privacy Policy and obligations with respect to Personal Information.  Failure to do so may result in disciplinary action, if warranted, up to and including termination of employment.

 

ARI is committed to assisting Individuals in protecting their privacy and exercising their rights under thie Privacy Policy and applicable laws.  Individuals making complaints or reporting potential violations of the Privacy Policy shall not be subject to any form of retaliation.  In addition, report of potential violations may be made on an anonymous basis.

 

For complaints that cannot be resolved between ARI and the complainant, ARI 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 Principles.

 

Contact Information:

American River International Inc.

% Privacy Officer

1229 Old Walt Whitman Road

Melville, New York  11747

privacyofficer@americanriverintl.com

 

If you feel ARI may not have abided by the US-EU Safe Harbor Privacy Principles, you may contact ARI at the address above or the US Federal Trade Commission.


Changes to this Safe Harbor Privacy Policy:  This policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles.  Appropriate public notice will be given concerning such amendments.