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SAFE HARBOR PRIVACY POLICY
CP Document Technologies respects individual privacy and values the confidence of its clients, employees, business partners and others. Not only do we strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which we do business, but we also make every effort to uphold the highest ethical standards in our business practices. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that CP Document Technologies follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the fifteen member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) to the United States.
SAFE HARBOR
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. The EEA also has recognized the U.S. Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). Consistent with its commitment to protect personal privacy, CP Document Technologies adheres to the Safe Harbor Principles.
SCOPE
This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by CP Document Technologies in the United States from the European Economic Area, in any format including electronic, paper or verbal.
DEFINITIONS
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that uses personal information provided by CP Document Technologies to perform tasks on behalf of and under the instructions of CP Document Technologies.
"CP Document Technologies" means CP Document Technologies Inc., its predecessors, successors, subsidiaries, and divisions.
"Personal information" means any information or set of information that identifies or could be used by or on behalf of CP Document Technologies to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
PRIVACY PRINCIPLES
The privacy principles in this Policy are based on the Safe Harbor Principles.
NOTICE and CHOICE: CP Document Technologies, at the direction of its clients, may collect data in the EEA that is relevant to the client’s matter. Individuals from whom CP Document Technologies collects data are informed about the purposes for which data is collected and how it will be used, the types of non-agent third parties to which CP Document Technologies discloses that information, and the choices and means, if any, CP Document Technologies offers individuals for limiting the use and disclosure of their personal information. To the extent permitted by the Safe Harbor Agreement, CP Document Technologies reserves the right to process personal information without the knowledge of individuals involved.
DATA INTEGRITY: CP Document Technologies uses personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized.
DISCLOSURES AND TRANSFERS: CP Document Technologies will not knowingly disclose an individual’s personal information to a third party without the consent of its client unless one or more of the following is true:
• We have the individual's permission to make the disclosure;
• The disclosure is required by law or professional standards;
• The information in question is publicly available;
• The disclosure is reasonably necessary for the establishment or defense of legal claims;
• The disclosure is reasonably related to the sale or disposition of all or part of our business;
CP Document Technologies 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), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Hungary and Switzerland).
ACCESS AND CORRECTION: Upon request, CP Document Technologies will grant individuals reasonable access to personal information that it holds about them. In addition, CP Document Technologies will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY:CP Document Technologies takes reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT: CP Document Technologies uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. Any employee that CP Document Technologies determines is in violation of this policy will be subject to disciplinary action.
We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.
If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using the American Arbitration Association as a third party resolution provider.
CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to:
CP Document Technologies
Attn: Jeremy Lindahl
350 S. Grand Ave.
Los Angeles CA 90071
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. We will post any revised policy on this website.
EFFECTIVE DATE: 11/17/2009
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