High-value address solutions that are compliant with data protection regulations.

Size: px
Start display at page:

Download "High-value address solutions that are compliant with data protection regulations."

Transcription

1 High-value address solutions that are compliant with data protection regulations. 1. Germany s Federal Data Protection Act (BDSG) in overview The German Federal Data Protection Act applies to the collection, processing and use of personal data. The opt-out solution which had been used to date was revoked when the amended Federal Data Protection Act went into force in September Instead of the previous opt-out solution, the data subject's consent is now required before personal data can be used for advertising purposes. There are 7 exceptions to the consent requirement: 1. Advertising aimed at existing customers One s own products or services may be advertised to private customers or business customers 1 provided that the data was collected from the data subject. When the data is collected directly from the data subject, the individual must be informed at the time the data is collected of the plans to use that data for advertising purposes and of the option of refusing consent to the use of one's data for advertising purposes. 2. Advertising aimed at interested parties One s own products or services may be advertised to interested parties 2 provided that the data was collected from the data subject. When the data is collected directly from the data subject, the individual must be informed at the time the data is collected of the plans to use that data for advertising purposes and of the option of refusing consent to the use of one's data for advertising purposes. 3. Data from directories that are available to the public It is lawful to advertise one's own or third-party products and services using data from publicly accessible directories B2B advertising Advertising that is related to the individual s occupation/employment and is sent to the individual s work address is lawful. This applies to natural persons (a company s employees) and to self-employed persons and freelancers. 1 A customer relationship exists if there is an underlying legal transaction such as a sales contract or the purchase of goods. 2 A relationship with an interested party exists if there is an underlying quasi-legal obligation, such as a request for bis or information. 3 Publicly-accessible directories are, for example, address lists, telephone directories and business directories (copyrights must be observed). Deutsche Post Direkt GmbH Telephone: Page 1/ Troisdorf, Germany

2 5. Advertising to solicit donations Organizations that enjoy preferential tax treatment, such as non-profit associations and political parties, may solicit donations. The main focus of this advertising must be on soliciting donations. It can however also be combined with other advertising. By contrast, campaign advertising by political parties is not privileged. 6. Transparent transfer It is lawful to transfer address data when the advertising material indicates the body 4 that originally collected it. 7. Transparent use It is lawful to transfer address data when the advertising material indicates the controller 5 that is responsible for its use. The following applies to all seven exceptions to the consent provision: Additional data that does not have to be collected from the data subject, such as selection criteria, may be added to and stored with the recipient data. 2. The BDSG s impact on Deutsche Post Direkt products and services The use of address solutions enables and/or optimizes direct advertising. Deutsche Post Direkt offers the entire range of professional address management services from address cleansing to enrichment and analysis all the way to address rental services. Deutsche Post Direkt markets personal data in accordance with the provisions of Section 29 of Germany's Federal Data Protection Act. In addition to address data such as name and address, personal data also includes additional information about the data subject's credit standing 6, consumer patterns and buying intentions. In addition to personal data, Deutsche Post Direkt offers target group attributes for enrichment, analysis and selection purposes; these attributes are based on statistical data. 2.1 The BDSG s impact on address cleansing Maintaining and updating address databases for existing customers and interested parties is lawful. When the requirements for an exception are met for advertising aimed at existing customers or for advertising aimed at interested parties, companies may use data on existing customers and interested parties to advertise their own products and services when this data was collected directly from the data subjects or from publicly accessible sources. Furthermore, Section 35 (1), first sentence of the Federal Data Protection Act even establishes an obligation to rectify incorrect address data. 4 The body that originally collected the data is the body that collected the data for the first time from the data subject or collected the data from a directory that is available to the public. 5 That person or body which collects, processes or uses the personal data for itself or has this done on its behalf by others. Deutsche Post Direkt GmbH Telephone: Page 2/ Troisdorf, Germany

3 Other companies' private customer data is cleansed on the basis of Deutsche Post Direkt's postal reference file. Containing more than 190 million current and past private addresses, this database is unique in Germany in terms of its size, completeness and up-to-dateness. Deutsche Post's address verification service is one of the services used to keep the address information current on an ongoing basis. For this, Deutsche Post mail carriers check and confirm whether addresses are written correctly and are deliverable. In addition, changes in postal codes and thousands of relocation notifications a day are incorporated into the postal reference file, insofar as the data subject has consented to the disclosure of the new address. Information on addressees who have died is provided to Deutsche Post Direkt by survivors of the deceased. This information is made available on a voluntary basis under a cooperation agreement with the Association of German Undertakers (Bundesverband Deutscher Bestatter). In Germany, there is no central file containing the address information of people who have died. Moreover, Germany's data protection law prohibits the retrieval of this information from civil registers. Despite extensive efforts to keep address data up-todate, mail items may still be returned because they are undeliverable. For this reason, Deutsche Post Direkt utilizes cooperation partner information regarding deceased persons in order to cleanse companies private customer data: SCHUFA Holding AG receives the addresses of deceased persons from its approx. 8,500 contract partners, which include all the major banks, as well as private and regional banks with retail banking. Furthermore, Deutsche Post Direkt processes addresses of deceased persons, as provided on a voluntary basis by their survivors, within the framework of a cooperation agreement with the Association of German Undertakers (Bundesverband Deutscher Bestatter). Despite extensive efforts to keep address data up-to-date, mail items may still be returned because they are undeliverable. 2.2 The BDSG s impact on address enrichment Deutsche Post Direkt offers statistical information and additional personal information for address enrichment purposes. Enrichment is a prerequisite for the analysis and segmentation of customer addresses and/or the exact target-group-based selection of rental data Statistical data In addition to geocoordinates and risk indices, statistical data includes first and foremost micro-geographical information from the microdialog database. This database contains socio-demographic, consumer and structural data plus information regarding area and region, certain industries and lifestyle. The data is aggregated at the microcell level with an average of 6.6 households. Probability statements are used to determine which target group attributes are represented in the microcell. It is not known whether these approximate statistical values such as values related to a specific purchasing behavior actually apply to persons in the microcell. The microdialog database contains no data which would allow the identification of the data subject and it is not subject to the BDSG. Microgeographic information is kept strictly separate from rental data. Accordingly, statistical probability statements are not stored Deutsche Post Direkt GmbH Telephone: Page 3/ Troisdorf, Germany

4 together with personal address data. For each individual customer order, a one-time selection is made solely at the microcell level and the result is then populated with the available address data. This process ultimately produces a file that contains only addresses and no additional information. The selection at the microcell level is then deleted. In the process, personal data and statistical data not only from Deutsche Post Direkt but also from other advertisers must always be stored separately from one another. In other words, a data record containing personal data may not at the same time contain statistical features as well. Enriching address lists of existing customers, interested parties and rental data with statistical information is lawful Personal additional information Deutsche Post Direkt continues to offer additional personal information such as telephone numbers or information regarding an individual's credit standing. 6 Enriching address lists of existing customers or interested parties with personal information is lawful when the company has a legitimate interest Impact of the BDSG on address analysis Amendment I (scoring) led to a number of new provisions for the transfer of data to rating agencies and the use of scoring procedures in connection with a contractual relationship. This does not apply to scoring for the selection of addresses for advertising purposes when the advertising contains no directly binding offer of a contract. Advertising usually represents an invitation to submit an offer; for example, when a catalog with an order form is mailed. For this reason, the analysis of address databases for existing customers or interested parties is lawful as long as any mailing that is generated from it does not contain a directly binding offer of a contract. Under these conditions, conducting an analysis for the purpose of selecting rental data is also lawful. Deutsche Post Direkt GmbH Telephone: Page 4/ Troisdorf, Germany

5 2.4 Impact of the BDSG on address renting Deutsche Post Direkt offers advertisers a broad range of target group addresses which may be used in conformance with current data protection law for customer acquisition purposes. 6 Source: arvato infoscore 7 Advertising is also a legitimate interest. 8 Lettershop, data center Renting of consumer addresses from the rental database Deutsche Post Direkt markets the consumer addresses from its rental database under the provision that the requirements are met for an exception based on transparent use. Therefore, using address data for advertising third-party products and services is lawful when the advertising indicates the controller that is responsible for the use of the addresses. Data transfer: Deutsche Post Direkt does not transfer the address data directly to the advertiser but rather makes it available to the contracted letter shop which is in charge of printing and mailing. Data protection considerations: The recipient of the mailing must be informed of the option of refusing consent to the use of personal data for advertising purposes. It must also be clear from the advertising that Deutsche Post Direkt is the controller responsible for the use of the data Brokering of address lists Deutsche Post Direkt brokers the rights of use for third-party address data (so-called list-broking addresses) provided that the requirements for an exception are met based on transparent use. Therefore, using address data for advertising third-party products and services when the advertising indicates the controller that is responsible for the use of the addresses. Deutsche Post Direkt GmbH Telephone: Page 5/ Troisdorf, Germany

6 Data transfer: Deutsche Post Direkt does not transfer the address data directly to the advertiser but rather makes it available to the contracted letter shop which is in charge of printing and mailing. Data protection considerations: The recipient of the mailing must be informed of the option of refusing consent to the use of personal data for advertising purposes. It must also be clear from the advertising that the list owner is the controller responsible for the use of the data Renting of business addresses When the requirements for an exception are met for B2B advertising, advertising that is related to the individual's occupation/employment and is sent to the individual's work address is lawful. This applies to natural persons (a company's employees) and to self-employed persons and freelancers. Data transfer: Deutsche Post Direkt may transfer the address data directly to advertisers. Data protection considerations: The recipients of the mailing must be informed of their right to refuse their consent to the use of their data for advertising purposes Maintenance of the rental data The rental data is maintained using Deutsche Post Direkt's postal reference file. Containing more than 190 million current and past private addresses, this database is unique in Germany in terms of its size, completeness and up-to-dateness. Deutsche Post's address verification service, among others, is used to keep the address information current on an ongoing basis. For this, Deutsche Post mail carriers check and confirm whether addresses are written correctly and are deliverable. In addition, changes in postal codes and thousands of relocation notifications a day are incorporated into the postal reference file, insofar as the data subject has consented to the disclosure of the new address. Information on addressees who have died is provided to Deutsche Post Direkt by survivors of the deceased. This information is made available on a voluntary basis under a cooperation agreement with the Association of German Undertakers (Bundesverband Deutscher Bestatter). In Germany, there is no central file containing the address information of people who have died. Moreover, German data protection law prohibits the retrieval of this information from civil registers. Despite extensive efforts to keep address data up-to-date, mail items may be returned because they are undeliverable or because the rental data contains the addresses of persons who are no longer living. For this reason, Deutsche Post Direkt utilizes cooperation partner information regarding deceased persons in order to maintain rental data: SCHUFA Holding AG receives the addresses of deceased persons from its approx. 8,500 contract partners, which include all the major banks, as well as private and regional banks with retail banking. Furthermore, Deutsche Post Direkt processes addresses of deceased persons, as provided on a voluntary basis by their survivors, within the framework of a cooperation agreement with the Deutsche Post Direkt GmbH Telephone: Page 6/ Troisdorf, Germany

7 Association of German Undertakers (Bundesverband Deutscher Bestatter). Despite extensive efforts to keep address data up-to-date, mail items may still be returned because they are undeliverable. 2.5 Information which data protection law requires advertising to include The information required by data protection law must be noticeably placed on the advertisement, such as in a footer to the mailing, on order forms or on the inside of the cover page of the catalog Reference to the controller When consumer addresses are rented from the rental database, this reference should read as follows: Controller within the meaning of the Federal Data Protection Act (BDSG): Deutsche Post Direkt GmbH, Postfach , Wuppertal. In the case of list-broking addresses, the relevant list broker is named as the controller. The data subject's legal right to refuse to consent at any time for the use or transfer of personal data by a controller is ensured by Deutsche Post Direkt's use of an internal blocking list. In addition, whenever there is an order, Deutsche Post Direkt undertakes to compare the data with the 'Robinson list' of the German direct-response marketing association Deutscher Dialogmarketing Verband. Blocking notices are put in place and inquiries about the origin of data answered without delay. This is done in the interest of the data subjects as well as for the purpose of avoiding complaints vis-à-vis companies that advertise Reference to the option of refusing to consent to the use of one s data for advertising purposes The sender s identity and the recipient s right not to consent to the use of his/her data must be indicated namely, on every piece of advertising regardless of whether it is sent to existing customers, new customers, business persons or private individuals. Example text: Wenn Sie künftig unsere Informationen und Angebote nicht mehr erhalten möchten, können Sie der Verwendung Ihrer Daten für Werbezwecke widersprechen. Teilen Sie uns dies bitte möglichst schriftlich unter Beifügung des Werbemittels und Angabe Ihres Namens und Ihrer Anschrift an unsere Adresse mit. [Translation for this proposed wording for your information: If you do not wish to receive our information and offers in the future, you can object to the use of your data for advertising purposes. If you wish to object, please notify us in writing (if possible) to our address and enclose the advertising material and your name and address details.] Deutsche Post Direkt GmbH Telephone: Page 7/ Troisdorf, Germany

8 3. Deutsche Post Direkt and data protection authorities Deutsche Post Direkt is one of the leading German address service providers and, as such, maintains close contact with representatives of the data protection authorities. As a company that processes personal data, it is required to notify the North Rhine-Westphalia Commissioner for Data Protection and Freedom of Information when it processes personal data. Moreover, Deutsche Post falls under the direct jurisdiction of the Federal Commissioner for Data Protection and Freedom of Information with whom it has a regular dialog. Deutsche Post Direkt's own data protection officer is frequently included in this dialog for monitoring and consultation purposes. 4. Data protection and data security measures taken by Deutsche Post Direkt Deutsche Post Direkt employees have undertaken in writing to comply with the obligation to maintain confidentiality pursuant to Section 5 of the Federal Data Protection Act and have informed themselves about any other existing obligations that customers may have regarding confidentiality such as banking secrecy or the protection of social data. Organizational and security measures ensure that only authorized employees have access to the data. In the area of address rental, Deutsche Post Direkt works only with letter shops that are members of the German Dialog Marketing Association (DDV), comply with data protection regulations and requirements, and submit confirmation that the address data was deleted following completion of the customer's order. Control addresses in the rental batch ensure that data is not forwarded to other parties. In the case of online address validation/collation, Deutsche Post Direkt complies with the latest security standards. Whenever data is transferred to or from its servers, Deutsche Post Direkt uses not only customized encryption processes but also encryption techniques similar to those used, for example, in online banking. The techniques Deutsche Post Direkt uses for encryption and authentication range from the use of 'https' for data transfers to virtual private networks. The most secure way to transfer address databases for the purpose of cleansing or updating customer data or to transfer rental data is the FTP transmission offered via the online services of Deutsche Post Direkt. In order to use the FTP transmission, companies are given user access and create their own password. As an additional security measure, companies can opt to transfer their data using password protection or PGP encryption. Deutsche Post Direkt has been certified according to the industry standard ISO on the basis of IT Baseline Protection standards set forth in IT-Grundschutz. Germany's Federal Office for Information Security (BSI) certified the business processes used in the ADDRESSFACTORY product family for cleansing and enriching customer addresses and Deutsche Post Direkt's online services (/online-services) with their integrated data exchange platform. This certification documents that Deutsche Post Direkt has implemented special technical and organizational security measures required by Section 9 of the Federal Data Deutsche Post Direkt GmbH Telephone Page 8/9 Last revised: Troisdorf, Germany 05/08/2014

9 Protection Act for processing personal data on behalf of others. The BSI certification releases customers from the obligation to monitor Deutsche Post Direkt as contractor, as otherwise required by data protection law. 5. Deutsche Post Direkt is a member of the German Dialog Marketing Association Deutsche Post Direkt is a member of the German Dialog Marketing Association (DDV) and, as such, guarantees through regular certification the highest level of professionalism and quality. In order to receive the DDV seal of approval for quality and service, important requirements must be met. These include training and instructing employees in data protection, ensuring transparent order processing and documentation, and compliance with technical and organizational data protection measures. DDV members are audited annually. Consequently, advertisers can be sure that members uphold service quality and data protection requirements. As a result, the DDV seal of approval for quality and service is also an important criterion when selecting or commissioning service providers. Disclaimer: This additional information does not replace a legal examination of the respective case. Although content is carefully reviewed, Deutsche Post Direkt assumes no liability for its accuracy, completeness or up-to-dateness. Deutsche Post Direkt GmbH Telephone Page 9/9 Last revised: Troisdorf, Germany 05/08/2014

DDV Declaration (VE 12/2009) Commissioned Data Processing and Data Treatment

DDV Declaration (VE 12/2009) Commissioned Data Processing and Data Treatment DDV Declaration (VE 12/2009) Commissioned Data Processing and Data Treatment Service provider: (in the following Service Provider ) Street, number: Country: ZIP code, city: E-mail address: Website: www...

More information

DDV Declaration Commissioned Data Processing and Data Treatment (Version: 09/2009)

DDV Declaration Commissioned Data Processing and Data Treatment (Version: 09/2009) DDV Declaration Commissioned Data Processing and Data Treatment (Version: 09/2009) Service provider: (in the following Service Provider ) Street, number ZIP code, city E-mail address Internet addresses

More information

Code of Conduct. Corporate Data Protection. We make ICT strategies work

Code of Conduct. Corporate Data Protection. We make ICT strategies work Corporate Data Protection Code of Conduct for the Protection of the Individual s Right to Privacy in the Handling of Personal Data within the Deutsche Telekom Group 2010 / 04 We make ICT strategies work

More information

ChangeIt Privacy Policy - Canada

ChangeIt Privacy Policy - Canada ChangeIt Privacy Policy - Canada 1. Policy on Privacy of Personal Information Formulating Change Inc. ( FCI, we, us or our ) is committed to protecting the privacy and security of your Personal Information

More information

PREPLY PRIVACY POLICY

PREPLY PRIVACY POLICY PREPLY PRIVACY POLICY Effective Date: November 21, 2012. Welcome to Preply! This Privacy Policy discloses FindGuru, Inc. s ( Preply, we, us or our ) privacy practices and procedures in connection with

More information

PRIVACY POLICY. Mil y Un Consejos Network. Mil y Un Consejos Network ( Company or we or us or our ) respects the privacy of

PRIVACY POLICY. Mil y Un Consejos Network. Mil y Un Consejos Network ( Company or we or us or our ) respects the privacy of PRIVACY POLICY Mil y Un Consejos Network Version Date: April 15th 2010 GENERAL Mil y Un Consejos Network ( Company or we or us or our ) respects the privacy of its users ( user or you ) whether they use

More information

eprivacyseal GmbH Criteria catalogue EU November 2013

eprivacyseal GmbH Criteria catalogue EU November 2013 eprivacyseal GmbH Criteria catalogue EU November 2013 The EPS data privacy seal certifies for the respective applicant that its product or service is in line with the detailed criteria in the following

More information

Data Processing Agreement for Oracle Cloud Services

Data Processing Agreement for Oracle Cloud Services Data Processing Agreement for Oracle Cloud Services Version December 1, 2013 1. Scope and order of precedence This is an agreement concerning the Processing of Personal Data as part of Oracle s Cloud Services

More information

Privacy Policy. MSI may collect information from you on a voluntary basis when you:

Privacy Policy. MSI may collect information from you on a voluntary basis when you: Last Updated: January 8, 2015 Privacy Policy Mind Sports International (MSI) respects the privacy rights of our customers and online visitors, and has adopted this privacy policy ("Privacy Policy") to

More information

Revelian Pty Ltd ABN 58 089 022 202 Privacy Policy Effective 1 September 2014

Revelian Pty Ltd ABN 58 089 022 202 Privacy Policy Effective 1 September 2014 Revelian Pty Ltd ABN 58 089 022 202 Privacy Policy Effective 1 September 2014 OUR COMMITMENT Your privacy is important to us. This document explains how Revelian collects, handles, uses and discloses your

More information

Astaro Services AG Rheinweg 7, CH-8200 Schaffhausen. Supplementary data protection agreement. to the license agreement for license ID: between

Astaro Services AG Rheinweg 7, CH-8200 Schaffhausen. Supplementary data protection agreement. to the license agreement for license ID: between Astaro Services AG Rheinweg 7, CH-8200 Schaffhausen Supplementary data protection agreement to the license agreement for license ID: between...... represented by... Hereinafter referred to as the "Client"

More information

PRIVACY AND SECURITY POLICY

PRIVACY AND SECURITY POLICY assess, align, achieve PRIVACY AND SECURITY POLICY ath Power Consulting is a professional market research and consulting firm. We are committed to maintaining the privacy of our website users, clients,

More information

Privacy Policy documents for

Privacy Policy documents for Privacy Policy documents for Praendex Incorporated doing business as PI Worldwide Product User Privacy Policy - For Customers, as well as those invited to our websites to complete a PI Survey or SSAT General

More information

Privacy Policy. Effective Date: November 20, 2014

Privacy Policy. Effective Date: November 20, 2014 Privacy Policy Effective Date: November 20, 2014 Welcome to the American Born Moonshine website (this Site ). This policy describes the Privacy Policy (this Policy ) for this Site and describes how Windy

More information

7.08.2 Privacy Rules for Customer, Supplier and Business Partner Data. Directive 7.08 Protection of Personal Data

7.08.2 Privacy Rules for Customer, Supplier and Business Partner Data. Directive 7.08 Protection of Personal Data Akzo Nobel N.V. Executive Committee Rules 7.08.2 Privacy Rules for Customer, Supplier and Business Partner Data Source Directive Content Owner Directive 7.08 Protection of Personal Data AkzoNobel Legal

More information

Corporate Policy. Data Protection for Data of Customers & Partners.

Corporate Policy. Data Protection for Data of Customers & Partners. Corporate Policy. Data Protection for Data of Customers & Partners. 02 Preamble Ladies and gentlemen, Dear employees, The electronic processing of virtually all sales procedures, globalization and growing

More information

(a) the kind of data and the harm that could result if any of those things should occur;

(a) the kind of data and the harm that could result if any of those things should occur; Cloud Computing This information leaflet aims to advise organisations on the factors they should take into account in considering engaging cloud computing. It explains the relevance of the Personal Data

More information

We will not collect, use or disclose your personal information without your consent, except where required or permitted by law.

We will not collect, use or disclose your personal information without your consent, except where required or permitted by law. HSBC Privacy Notice HSBC's Privacy Principles HSBC Bank Canada is a subsidiary of HSBC Holdings plc which, together with its subsidiaries and affiliates, is one of the world s largest banking and financial

More information

Brussels, 20 July 2010 (Case 2009-0215) 1. Proceedings

Brussels, 20 July 2010 (Case 2009-0215) 1. Proceedings Opinion on a notification for Prior Checking received from the Data Protection Officer of the European Investment Bank (EIB) concerning procedures related to "360 Leadership feedback report" Brussels,

More information

AIG INSURANCE COMPANY OF CANADA Privacy Principles

AIG INSURANCE COMPANY OF CANADA Privacy Principles AIG and Individual Privacy We at AIG Insurance Company of Canada (referred to as AIG, we, our, or us ) abide by these and want you, our applicants, policyholders, insureds, claimants, and any other individuals

More information

Talen Energy Corporation Website Privacy Notice

Talen Energy Corporation Website Privacy Notice Talen Energy Corporation Website Privacy Notice Talen Energy Corporation and its affiliates (collectively referred to in this notice as Talen Energy, we, us, our and other similar pronouns), have developed

More information

Service Description for the Registration and Administration of Domain Names by Swisscom

Service Description for the Registration and Administration of Domain Names by Swisscom Service Description for the Registration and Administration of Domain Names by Swisscom 1 Area of application This Service Description govern the conditions for the registration, administration, and use

More information

ESTRO PRIVACY AND DATA SECURITY NOTICE

ESTRO PRIVACY AND DATA SECURITY NOTICE ESTRO PRIVACY AND DATA SECURITY NOTICE This Data Privacy and Security Policy is a dynamic document, which will reflect our continuing vigilance to properly handle and secure information that we are trusted

More information

GRTGAZ NETWORK TRANSMISSION CONTRACT

GRTGAZ NETWORK TRANSMISSION CONTRACT Page 1 of 9 GRTGAZ NETWORK TRANSMISSION CONTRACT APPENDIX A3 STANDARD EVIDENCE AGREEMENT English translation for information. Disclaimer The present translation is not binding and is provided by GRTgaz

More information

Annex to the General Terms and Conditions: Terms and Conditions for Electronic Banking Services of the Raiffeisen Bank

Annex to the General Terms and Conditions: Terms and Conditions for Electronic Banking Services of the Raiffeisen Bank Version 2009 Version 2013 1. Purpose These Terms and Conditions supplement the General Terms and Conditions of the Raiffeisen bank and regulate the communication between the customer and the Raiffeisen

More information

Privacy Policy. Ignite your local marketing

Privacy Policy. Ignite your local marketing Privacy Policy Ignite your local marketing Contents 1) Introduction... 3 2) What is your personal information?... 3 3) What personal information do we collect and hold?... 3 4) How do we collect your personal

More information

Data Protection Policy.

Data Protection Policy. Data Protection Policy. Data Protection Policy Foreword 2 Foreword Ladies and Gentlemen, In the information age, we offer customers the means to be always connected, even in their cars. This requires data

More information

Zubi Advertising Privacy Policy

Zubi Advertising Privacy Policy Zubi Advertising Privacy Policy This privacy policy applies to information collected by Zubi Advertising Services, Inc. ( Company, we or us ), on our Latino Emoji mobile application or via our Latino Emoji

More information

Privacy Statement Relating to the Collection, Use and Disclosure of Personal Data & Customer Information

Privacy Statement Relating to the Collection, Use and Disclosure of Personal Data & Customer Information Privacy Statement Relating to the Collection, Use and Disclosure of Personal Data & Customer Information Safeguarding personal data and customer information and using it in a lawful manner, consistent

More information

SUITE SOLUTIONS MEMBERSHIP GUIDELINES Clients using EZ-Filing Inc. Software

SUITE SOLUTIONS MEMBERSHIP GUIDELINES Clients using EZ-Filing Inc. Software SUITE SOLUTIONS MEMBERSHIP GUIDELINES Clients using EZ-Filing Inc. Software The following procedures are needed to establish your account in order to download three bureau credit reports into your bankruptcy

More information

The Winnipeg Foundation Privacy Policy

The Winnipeg Foundation Privacy Policy The Winnipeg Foundation Privacy Policy The http://www.wpgfdn.org (the Website ) is operated by The Winnipeg Foundation (the Foundation ). The Winnipeg Foundation Privacy Policy Foundation is committed

More information

Privacy Policy - LuxTNT.com

Privacy Policy - LuxTNT.com Privacy Policy - LuxTNT.com Overview TNT Luxury Group Limited (the owner of LuxTNT.com). knows that you care how information about you is used and shared, and we appreciate your trust that we will do so

More information

DailyMailz may collect and process the following personal information about you:

DailyMailz may collect and process the following personal information about you: Privacy Policy DailyMailz is committed to preserving the privacy of all visitors to its website www.dailymailz.nl ("Website"). This privacy policy along with DailyMailz s terms and conditions of use and

More information

Mid Carolina CU Internet Online Banking Services Terms and Conditions

Mid Carolina CU Internet Online Banking Services Terms and Conditions Mid Carolina CU Internet Online Banking Services Terms and Conditions This Agreement is the contract which covers your and our rights and responsibilities concerning the Home Banking services offered to

More information

PRIVACY POLICY. Introduction

PRIVACY POLICY. Introduction PRIVACY POLICY Introduction Thomas & Darden Inc. ( Company or We ) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information

More information

Please read this Policy carefully. Your continued use of our sites means that you understand and consent to the terms of this Policy.

Please read this Policy carefully. Your continued use of our sites means that you understand and consent to the terms of this Policy. EFFECTIVE: February 2016 Version 1.2 CHECK 'N GO PRIVACY POLICY This Privacy Policy ("Policy") applies to the use of Check 'n Go (the "Company") online sites and any Company affiliate or subsidiary sites.

More information

Troy Cablevision, Inc. Subscriber Privacy Policy

Troy Cablevision, Inc. Subscriber Privacy Policy Troy Cablevision, Inc. Subscriber Privacy Policy Troy Cablevision, Inc. ( Troy Cable ) is committed to protecting and securely maintaining our customers privacy. The following privacy policy applies to

More information

If you have any questions about our privacy practices, please refer to the end of this privacy policy for information on how to contact us.

If you have any questions about our privacy practices, please refer to the end of this privacy policy for information on how to contact us. c4m Privacy Policy Last Modified: July 20, 2015 Colbette II Ltd., Block 1, 195-197 Old Nicosia-Limassol Road, Dali Industrial Zone, Cyprus 2540 (hereinafter "c4m", Colbette we", "our" or "us") is always

More information

Best Practices in Data Management - A Guide for Marketers -

Best Practices in Data Management - A Guide for Marketers - Best Practices in Data Management - A Guide for Marketers - Prepared with support from the Office of the Privacy Commissioner of Canada s Contributions Program INTRODUCTION As consumers personal information

More information

Data protection compliance checklist

Data protection compliance checklist Data protection compliance checklist What is this checklist for? This checklist is drawn up on the basis of analysis of the relevant provisions of European law. Although European law aims at harmonizing

More information

Agreement on Software and Database Terms of Use and Maintenance Terms

Agreement on Software and Database Terms of Use and Maintenance Terms Agreement on Software and Database Terms of Use and Maintenance Terms between Radlabor GmbH, Schwarzwaldstr. 175 D-79117 Freiburg Germany and - hereinafter Provider - the company or natural person, denominated

More information

ONLINE CREDIT REPORTING S SUITE SOLUTIONS MEMBERSHIP GUIDELINES

ONLINE CREDIT REPORTING S SUITE SOLUTIONS MEMBERSHIP GUIDELINES ONLINE CREDIT REPORTING S SUITE SOLUTIONS MEMBERSHIP GUIDELINES The following procedures are needed to establish your account in order to download three bureau credit reports into your bankruptcy software.

More information

Ivy Tech Community College of Indiana

Ivy Tech Community College of Indiana Ivy Tech Community College of Indiana POLICY TITLE Family Educational Rights and Privacy Act (FERPA) POLICY NUMBER 3.6 (Former APPM 3.4) PRIMARY RESPONSIBILITY Student Affairs CREATION / REVISION / EFFECTIVE

More information

ONLINE PRIVACY POLICY

ONLINE PRIVACY POLICY ONLINE PRIVACY POLICY The City of New Westminster is committed to protecting your privacy. Any personal information collected, used or disclosed by the City is in accordance with the Freedom of Information

More information

H&R Block Digital Tax Preparation, Online, and Mobile Application Privacy Practices and Principles

H&R Block Digital Tax Preparation, Online, and Mobile Application Privacy Practices and Principles Privacy Notice H&R Block Digital Tax Preparation, Online, and Mobile Application Privacy Practices and Principles Protecting your information is important to us. The following guidelines set forth our

More information

Data controllers and data processors: what the difference is and what the governance implications are

Data controllers and data processors: what the difference is and what the governance implications are ICO lo : what the difference is and what the governance implications are Data Protection Act Contents Introduction... 3 Overview... 3 Section 1 - What is the difference between a data controller and a

More information

Online Lead Generation: Data Security Best Practices

Online Lead Generation: Data Security Best Practices Online Lead Generation: Data Security Best Practices Released September 2009 The IAB Online Lead Generation Committee has developed these Best Practices. About the IAB Online Lead Generation Committee:

More information

PRIVACY NOTICE. Last Updated: March 24, 2015

PRIVACY NOTICE. Last Updated: March 24, 2015 PRIVACY NOTICE Your access to and use of this website is governed by the TERMS OF WEBSITE USE and the following PRIVACY NOTICE. Please read them carefully as they constitute a legally binding agreement

More information

CITY OF LOCKPORT ELECTRIC AGGREGATION PROGRAM PLAN OF OPERATION AND GOVERNANCE. Background

CITY OF LOCKPORT ELECTRIC AGGREGATION PROGRAM PLAN OF OPERATION AND GOVERNANCE. Background CITY OF LOCKPORT ELECTRIC AGGREGATION PROGRAM PLAN OF OPERATION AND GOVERNANCE Background Enacted in August of 2007, the Illinois Power Agency Act (20 ILCS 3855/I-92) established the means for local governments

More information

Protecting your privacy

Protecting your privacy Protecting your privacy Table of Contents Answering your questions about privacy Your privacy... 1 Your consent... 1 Answering your questions about privacy... 2 About cookies... 9 Behavioural Advertising/Online

More information

Online Banking - Terms and Conditions

Online Banking - Terms and Conditions Online Banking - Terms and Conditions (updated 12/2015) Welcome to electronic banking at Capstone Bank. This Agreement and Disclosure Statement for Online Banking Services (the "Agreement") describes the

More information

DISCLAIMER, TERMS & CONDITIONS OF USE

DISCLAIMER, TERMS & CONDITIONS OF USE DISCLAIMER, TERMS & CONDITIONS OF USE Welcome to Universal Devices, Inc.'s online website. By accessing and using this website, you acknowledge that you have read, agree to, and are aware of the following

More information

Privacy Policy Version 1.0, 1 st of May 2016

Privacy Policy Version 1.0, 1 st of May 2016 Privacy Policy Version 1.0, 1 st of May 2016 THIS PRIVACY POLICY APPLIES TO PERSONAL INFORMATION COLLECTED BY GOCIETY SOLUTIONS FROM USERS OF THE GOCIETY SOLUTIONS APPLICATIONS (GoLivePhone and GoLiveAssist)

More information

HIPAA Employee Training Guide. Revision Date: April 11, 2015

HIPAA Employee Training Guide. Revision Date: April 11, 2015 HIPAA Employee Training Guide Revision Date: April 11, 2015 What is HIPAA? The Health Insurance Portability and Accountability Act of 1996 (also known as Kennedy- Kassebaum Act ). HIPAA regulations address

More information

Money One Federal Credit Union Pocket 2 Pocket Service E-SIGNATURE AND ELECTRONIC DISCLOSURES AGREEMENT

Money One Federal Credit Union Pocket 2 Pocket Service E-SIGNATURE AND ELECTRONIC DISCLOSURES AGREEMENT Money One Federal Credit Union Pocket 2 Pocket Service E-SIGNATURE AND ELECTRONIC DISCLOSURES AGREEMENT You are signing up to use the Pocket 2 Pocket service powered by Acculynk that allows you to send

More information

PRIVACY POLICY (LAST UPDATED: 29.05.2015)

PRIVACY POLICY (LAST UPDATED: 29.05.2015) PRIVACY POLICY (LAST UPDATED: 29.05.2015) CONTENTS 1 Personally Identifiable Information... 3 2 Collection of Personally Identifiable and Other Data and Information... 3 2.1 When visiting our website www.zanox.com...

More information

Abilities Centre collects personal information for the following purposes:

Abilities Centre collects personal information for the following purposes: Privacy Policy Accountability Abilities Centre is responsible for your personal information under its control. We have appointed a Privacy Officer who is accountable for our compliance with this Privacy

More information

Kaiser Permanente Affiliate Link Provider Web Site Application

Kaiser Permanente Affiliate Link Provider Web Site Application Kaiser Foundation Health Plan of Colorado Kaiser Permanente Affiliate Link Provider Web Site Application FOR PROVIDERS CONTRACTED WITH KAISER IN THE COLORADO REGION ONLY Page 1 of 7 Kaiser Permanente Affiliate

More information

PRIVACY POLICY. Privacy Statement

PRIVACY POLICY. Privacy Statement PRIVACY POLICY Privacy Statement Blue Care is one of Australia's leading providers of retirement living, community health, help at home services and aged care homes, caring for more than 12,500 people

More information

DAVIS SMITH ACCOUNTING ASSOCIATES, P.A.

DAVIS SMITH ACCOUNTING ASSOCIATES, P.A. DAVIS SMITH ACCOUNTING ASSOCIATES, P.A. 5582 Milford-Harrington Hwy. Harrington, DE 19952 (302) 398-4020 (302) 398-3665 fax Email: info@davis-smithaccounting.com Web site: www.davis-smithaccounting.com

More information

1.02 Authorized Recipient means an entity authorized by statute to receive background check information for noncriminal justice purposes.

1.02 Authorized Recipient means an entity authorized by statute to receive background check information for noncriminal justice purposes. SECURITY and MANAGEMENT CONTROL OUTSOURCING STANDARD The goal of this document is to provide adequate security and integrity for background check information while under the control or management of an

More information

SAMPLE RETURN POLICY

SAMPLE RETURN POLICY DISCLAIMER The sample documents below are provided for general information purposes only. Your use of any of these sample documents is at your own risk, and you should not use any of these sample documents

More information

ADVANCED CABLE COMMUNICATIONS WEBSITE PRIVACY POLICY COLLECTION AND USE OF INFORMATION FROM USERS

ADVANCED CABLE COMMUNICATIONS WEBSITE PRIVACY POLICY COLLECTION AND USE OF INFORMATION FROM USERS ADVANCED CABLE COMMUNICATIONS WEBSITE PRIVACY POLICY Advanced Cable Communications ( Company ) strives to offer visitors to its website (the Site ) the many advantages of Internet technology and to provide

More information

Web Sites Covered This policy covers NASBA.org and all other NASBA affiliated sites that link to this policy.

Web Sites Covered This policy covers NASBA.org and all other NASBA affiliated sites that link to this policy. NASBA.org Privacy Policy The National Association of State Boards of Accountancy (or NASBA, us, we ) recognizes the importance of privacy and is committed to protecting the privacy of individuals who use

More information

PRIVACY POLICY. Last Revised: June 23, 2014 1. About this Privacy Policy.

PRIVACY POLICY. Last Revised: June 23, 2014 1. About this Privacy Policy. Last Revised: June 23, 2014 1. About this Privacy Policy. PRIVACY POLICY This Privacy Policy is a statement by Active Data, Inc. ( Active Data ) that describes how we collect, store, process, and share

More information

This English translation of the Act on Regulation of the Transmission of Specified

This English translation of the Act on Regulation of the Transmission of Specified This English translation of the Act on Regulation of the Transmission of Specified Electronic Mail ( Act No. 26 of April 17, 2002) has been prepared in compliance with the Standard Bilingual Dictionary

More information

GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 2005 H 2 HOUSE BILL 629 Committee Substitute Favorable 5/18/05

GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 2005 H 2 HOUSE BILL 629 Committee Substitute Favorable 5/18/05 GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 0 H HOUSE BILL Committee Substitute Favorable //0 Short Title: Option to Freeze Credit Report. Sponsors: Referred to: March, 0 (Public) A BILL TO BE ENTITLED

More information

Privacy Policy. About Us and Our Purpose. Your Privacy is Our Mission

Privacy Policy. About Us and Our Purpose. Your Privacy is Our Mission Privacy Policy The purpose of this Privacy Policy is to describe and explain how we collect, use and distribute any personal information you provide to us. It also describes the options you have available

More information

Types of Information That May Be Collected

Types of Information That May Be Collected 1800 Tysons Blvd McLean, VA 22102 Suite 550 This privacy policy applies to the Web site located at www.washingtonredskinsoriginalamericansfoundation. org (the Website ). The Website is operated by The

More information

INERTIA ETHICS MANUAL

INERTIA ETHICS MANUAL SEVENTH FRAMEWORK PROGRAMME Smart Energy Grids Project Title: Integrating Active, Flexible and Responsive Tertiary INERTIA Grant Agreement No: 318216 Collaborative Project INERTIA ETHICS MANUAL Responsible

More information

We may collect the following types of information during your visit on our Site:

We may collect the following types of information during your visit on our Site: Privacy Policy This Privacy Policy (the Policy ) governs the use and collection of information that Horizon Broadcasting Group, LLC (collectively, "we," "our" or the "website") obtains from you while you

More information

Compliance Management Systems

Compliance Management Systems Certification Scheme Y03 Compliance Management Systems ISO 19600 ONR 192050 Issue V2.1:2015-01-08 Austrian Standards plus GmbH Dr. Peter Jonas Heinestraße 38 A-1020 Vienna, Austria E-Mail: p.jonas@austrian-standards.at

More information

Will Electric Aggregation Group. Electric Aggregation Plan of Operation and Governance. Will County Governmental League

Will Electric Aggregation Group. Electric Aggregation Plan of Operation and Governance. Will County Governmental League Will Electric Aggregation Group Electric Aggregation Plan of Operation and Governance Will County Governmental League 1 Electrical Aggregation Plan of Operation and Governance Enacted in August of 2007,

More information

Binding Corporate Rules ( BCR ) Summary of Third Party Rights

Binding Corporate Rules ( BCR ) Summary of Third Party Rights Binding Corporate Rules ( BCR ) Summary of Third Party Rights This document contains in its Sections 3 9 all provision of the Binding Corporate Rules (BCR) for Siemens Group Companies and Other Adopting

More information

The Business Enterprise Registration Act

The Business Enterprise Registration Act Please note: The text below is a translation of the original Norwegian Act. Should any doubt arise, the Norwegian text of the Act is valid and binding. The Business Enterprise Registration Act Latest update:

More information

The privacy of DataLogic CRM, Inc. s customers and affiliates is important to us. Therefore:

The privacy of DataLogic CRM, Inc. s customers and affiliates is important to us. Therefore: Privacy Policy DataLogic CRM, Inc. is committed to the security and privacy of our customer s data. This Privacy Policy explains our commitment to safeguarding our customers data and serves as our agreement

More information

Data Protection and Privacy Policy

Data Protection and Privacy Policy Data Protection and Privacy Policy 1. General This policy outlines Conciliation Resources commitments to respect the privacy of people s personal information and observe the relevant data protection legislation.

More information

1 Terms and Conditions Cloud + Managed Hosting

1 Terms and Conditions Cloud + Managed Hosting Cloud + Managed Hosting 1 1 Terms and Conditions Cloud + Managed Hosting 1. General - Scope The following terms and conditions apply to all business relationships between the customer and aixzellent -

More information

Act on Regulation of Transmission of Specified Electronic Mail ( Act No. 26 of April 17, 2002)

Act on Regulation of Transmission of Specified Electronic Mail ( Act No. 26 of April 17, 2002) この 特 定 電 子 メールの 送 信 の 適 正 化 等 に 関 する 法 律 の 翻 訳 は 平 成 十 七 年 法 律 第 八 十 七 号 まで の 改 正 ( 平 成 18 年 5 月 1 日 施 行 )について 法 令 用 語 日 英 標 準 対 訳 辞 書 ( 平 成 18 年 3 月 版 )に 準 拠 して 作 成 したものです なお この 法 令 の 翻 訳 は 公 定 訳 ではありません

More information

PRIVACY POLICY. What Information Is Collected

PRIVACY POLICY. What Information Is Collected PRIVACY POLICY This Privacy Policy applies to Web.com Group, Inc. (along with all subsidiaries, affiliates, successors and assigns thereof, referred to hereinafter collectively as Web.com, "we", "our"

More information

CLOUD COMPUTING FOR SMALL- AND MEDIUM-SIZED ENTERPRISES:

CLOUD COMPUTING FOR SMALL- AND MEDIUM-SIZED ENTERPRISES: CLOUD COMPUTING FOR SMALL- AND MEDIUM-SIZED ENTERPRISES: Privacy Responsibilities and Considerations Cloud computing is the delivery of computing services over the Internet, and it offers many potential

More information

Authorized. User Agreement

Authorized. User Agreement Authorized User Agreement CareAccord Health Information Exchange (HIE) Table of Contents Authorized User Agreement... 3 CareAccord Health Information Exchange (HIE) Polices and Procedures... 5 SECTION

More information

Corporate Guidelines for Subsidiaries (in Third Countries ) *) for the Protection of Personal Data

Corporate Guidelines for Subsidiaries (in Third Countries ) *) for the Protection of Personal Data Corporate Guidelines for Subsidiaries (in Third Countries ) *) for the Protection of Personal Data *) For the purposes of these Corporate Guidelines, Third Countries are all those countries, which do not

More information

Data Protection in Ireland

Data Protection in Ireland Data Protection in Ireland 0 Contents Data Protection in Ireland Introduction Page 2 Appointment of a Data Processor Page 2 Security Measures (onus on a data controller) Page 3 8 Principles Page 3 Fair

More information

Rise Broadband Networks, Inc. Privacy Policy and Customer California Privacy Rights. Effective date: January, 2016

Rise Broadband Networks, Inc. Privacy Policy and Customer California Privacy Rights. Effective date: January, 2016 Networks, Inc. Privacy Policy and Customer California Privacy Rights Effective date: January, 2016 knows Customers care about how their personally identifiable information ( Personal Information ) is used

More information

MIS Privacy Statement. Our Privacy Commitments

MIS Privacy Statement. Our Privacy Commitments MIS Privacy Statement Our Privacy Commitments MIS Training Institute Holdings, Inc. (together "we") respect the privacy of every person who visits or registers with our websites ("you"), and are committed

More information

At Cambrian, Your Privacy is Our Priority. Regardless of how you deal with us on the phone, online, or in person we have strict security measures

At Cambrian, Your Privacy is Our Priority. Regardless of how you deal with us on the phone, online, or in person we have strict security measures Privacy Policy At Cambrian, Your Privacy is Our Priority At Cambrian Credit Union, we know our members are concerned about the confidentiality and security of their personal information. This Policy ensures

More information

SUBSCRIBER PRIVACY NOTICE

SUBSCRIBER PRIVACY NOTICE PRIVACY AND SECURITY NewWave will provide you with a copy of its privacy notice at the time Service is installed, and annually afterwards, or as otherwise permitted by law. Customer can view the most current

More information

YOUR PRIVACY IS IMPORTANT TO SANDERSONS ARCHIVING SOLUTIONS LIMITED

YOUR PRIVACY IS IMPORTANT TO SANDERSONS ARCHIVING SOLUTIONS LIMITED YOUR PRIVACY IS IMPORTANT TO SANDERSONS ARCHIVING SOLUTIONS LIMITED SANDERSONS ARCHIVING SOLUTIONS LIMITED WEB SITE PRIVACY POLICY Policy last updated: 22 nd December 2014 This Policy is adopted by Sandersons

More information

Personal Data Act (1998:204);

Personal Data Act (1998:204); Personal Data Act (1998:204); issued 29 April 1998. Be it enacted as follows. General provisions Purpose of this Act Section 1 The purpose of this Act is to protect people against the violation of their

More information

GENERAL ELECTRIC COMPANY EMPLOYMENT DATA PROTECTION STANDARDS

GENERAL ELECTRIC COMPANY EMPLOYMENT DATA PROTECTION STANDARDS GENERAL ELECTRIC COMPANY EMPLOYMENT DATA PROTECTION STANDARDS December 2005 2 GENERAL ELECTRIC COMPANY EMPLOYMENT DATA PROTECTION STANDARDS I. OBJECTIVE... 1 II. SCOPE... 1 III. APPLICATION OF LOCAL LAWS...

More information

Surveying with CustomerGauge - Legal Considerations:

Surveying with CustomerGauge - Legal Considerations: Resource Sheet Surveying with CustomerGauge - Legal Considerations: Adam Dorrell Please Note this is not a legal document, and should be used for guidance only. You are advised to seek legal advice before

More information

Data Protection for the Guidance Counsellor. Issues To Plan For

Data Protection for the Guidance Counsellor. Issues To Plan For Data Protection for the Guidance Counsellor Issues To Plan For Author: Hugh Jones Data Protection Specialist Longstone Management Ltd. Published by the National Centre for Guidance in Education (NCGE)

More information

Annex to the General Terms and Conditions: Terms and Conditions for Electronic Banking Services of the Raiffeisen Bank Version 2013

Annex to the General Terms and Conditions: Terms and Conditions for Electronic Banking Services of the Raiffeisen Bank Version 2013 Annex to the General Terms and Conditions: Terms and Conditions for Electronic Banking Services of the Raiffeisen Bank Version 2013 1. Purpose These Terms and Conditions supplement the General Terms and

More information

McZeely Coterie, LLC Privacy Notice. Effective Date of this Privacy Notice: February 11, 2015.

McZeely Coterie, LLC Privacy Notice. Effective Date of this Privacy Notice: February 11, 2015. McZeely Coterie, LLC Privacy Notice Effective Date of this Privacy Notice: February 11, 2015. We at McZeely Coterie, LLC, the company that proudly brings you Plan Z by Zola ( Plan Z ), respect your concerns

More information