“Personal Information” or “Information” means information in any form which is about or pertaining to a specific individual, which can be linked to that individual, and which is transferred from the EU to the United States.
“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
For the avoidance of doubt, all references to Personal Information impliedly include Sensitive Personal Information, unless specifically addressed separately.
Company shall inform individuals of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which Company discloses or may disclose that Information. Company shall provide the individual with the choice and means for limiting 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 to Company, or as soon as practicable thereafter, and in any event before Company uses or discloses the Information for a purpose other than for which it was originally collected.
Company will offer individuals the opportunity to opt-out of whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For Sensitive Personal Information, Company will give individuals the opportunity to affirmatively or explicitly give their consent or opt-in to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
Company will obtain assurances from its agents that they will safeguard Personal Information consistently with this policy. Examples of appropriate assurances 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); being subject to the Swiss Federal Act on Data Protection; Safe Harbor certification by the agent; or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g. companies located in Canada). Where Company has knowledge that an agent is using or disclosing Personal Information or Sensitive Personal Information in a manner contrary to this policy, Company will take reasonable steps to prevent or stop the use or disclosure.
Company shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. These steps include maintaining appropriate physical, electronic and managerial procedures to safeguard and secure the Information.
Company cannot guarantee the security of Information on or transmitted via the internet.
Company shall only process Personal Information in a way that is compatible with and relevant to the purpose for which that Information was collected or authorized by the individual to whom it refers. To the extent necessary for those purposes, Company shall take reasonable steps to ensure that the Information is accurate, complete, current and reliable for its intended use.
Upon request, Company will grant individuals reasonable access to the Information which it holds about them. Additionally, Company will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete.
We encourage interested persons to raise any concerns using the contact information provided below, and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Safe Harbor Principles.
If a complaint or dispute cannot first be resolved through our internal process, we agree to participate in the following dispute resolution procedures in the investigation and resolution of complaints:
Questions, comments or complaints regarding Company’s Safe Harbor Policy or data collection and processing practices can be mailed or emailed to:
American Bureau of Shipping
16855 Northchase Drive
Houston, Texas 77060 USA
ATTN: Alexander Conser at email@example.com.
For further information on the Safe Harbor programs, please visit http://export.gov/safeharbor.