Altep, Inc. Safe Harbor Policy
Altep, Inc. recognizes that privacy and confidentiality are very important to our clients and vendor partners. In accordance with our corporate focus on personal responsibility, integrity and professionalism, we pledge to safeguard the security and confidentiality of any and all personal information that employees, clients and partners provide to us. This includes names, addresses, telephone numbers, email addresses and any information that can be linked to an individual. 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.") The Principles are intended to assist U.S. companies in satisfying European Union requirements regarding privacy and protection of personal information that is transferred from the EU to the United States. Altep, Inc. has elected to self-certify to the Department of Commerce that it adheres to the Safe Harbor Principles. This Safe Harbor Privacy Policy (the "Policy") outlines the principles and guidelines that Altep follows with respect to transfers of personal information from the European Union (EU) to the United States. SCOPE This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by Altep in the United States from the European Union, regardless of format. Information received in electronic and paper form, as well as verbally, is all subject to the Policy. To the degree that we collect and use personal information, we pledge to do so in a manner that complies with the laws of the countries in which we do business. IMPACT OF BUSINESS MODEL Altep performs data processing, hosting and conversion for its clients in preparation for legal discovery, as necessary for the establishment of legal claims or defenses. As such, we do not control the content of the ESI that we are asked to work with on our clients’ behalf. Clients and / or their Counsel determine which data elements are included in document review databases; with the exception of performing data imports, coding document fields and other data maintenance activities as directed by our clients, Altep does not collect or enter data into clients’ data repositories. At the direction of our clients, we may transmit data to third parties. Moreover, any access to or use of client data by Altep is incidental to our performance of our contractual obligations to our clients. Within the context of our own Sales and Marketing activities, Altep may collect personal information including names, addresses, phone numbers and e-mail addresses. Altep will take every reasonable measure to safeguard such information in accordance with the Safe Harbor Principles. Definitions Custodian: an individual whose data has been collected in preparation for the discovery phase of litigation. Altep processes and hosts custodian data for review by counsel; data that is determined to be responsive to the matter in question is produced, at the direction of the client, to opposing counsel and/or the Court. Agent: any third party that uses personal information provided to Altep to perform tasks on behalf of and under the instructions of Altep. PRIVACY PRINCIPLES The privacy principles in this Policy are based on the Safe Harbor Principles. NOTICE: As a provider of data processing, hosting and conversion services for its clients, Altep does not inform Custodians about the purposes for which their personal information was collected and used by its clients (typically, the individuals’ employers.) Altep relies on its clients to provide any required notices. If Altep receives personal information from its affiliates, partners or other entities in the EU, it will use such information in accordance with the notices such entities provided and the choices made by the individuals to whom such personal information relates. CHOICE: As a provider of data processing, hosting and conversion services for its clients, and by virtue of the nature of the discovery process, Altep cannot and does not offer Custodians an opportunity to choose (opt-out) whether their personal information 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. For personal information that is collected outside of the discovery process and used for non-discovery purposes (e-mail marketing campaigns, direct mail campaigns, etc.), Altep offers individuals an opportunity to opt-out / unsubscribe. Altep provides individuals with reasonable methods to exercise their choices. Altep does not disclose personal information to non-agent third parties. DATA INTEGRITY: As a provider of data processing and hosting services, Altep does not directly use the personal information that may be present in its clients’ data populations. However, throughout the course of its stewardship over each client’s data, Altep will take reasonable steps to ensure that all data that is collected is relevant to its intended use, accurate and complete. TRANSFERS TO AGENTS: Altep requires all employees and agents to sign and comply with a non-disclosure agreement that effectively safeguards personal information consistently with this Policy. If Altep has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Altep will take reasonable steps to prevent or stop the use or disclosure. ACCESS AND CORRECTION: Within the context of data that is collected and used for non-discovery purposes, Altep will grant individuals reasonable access to personal information that it holds about them upon request. Further, Altep will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Altep does not grant Custodians access to data that was collected in preparation for discovery / litigation. SECURITY: Altep will take every reasonable precaution to protect all data, including personal information, in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. ENFORCEMENT: Altep will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Altep determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment. DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to Altep’s Corporate Headquarters at the address below. Altep will investigate and attempt to resolve all questions, complaints and disputes regarding its use and disclosure of personal information in accordance with the Safe Harbor Principles and the guidelines contained in this Policy. Additionally, Altep has subscribed to the Trust-e online and offline Dispute Resolution service; in the event that a complaint or dispute cannot be resolved, Altep will contact Trust-e for arbitration and remediation. As part of our participation in safe harbor, we have agreed to the TRUSTe Dispute Resolution Requirements for disputes relating to our compliance with the Safe Harbor Privacy Framework If contacting us does not resolve your complaint, you may raise your complaint by contacting TRUSTe here , by fax at 415-520-3420, or mail at Watchdog Complaints, TRUSTe, 55 2nd Street, 2nd Floor, San Francisco, CA, USA 94105. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaints shared with the company. For information about TRUSTe or the operation of TRUSTe’s dispute resolution process, please visit TRUSTe or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English. CONTACT INFORMATION Questions or comments should be sent to Altep Corporate Headquarters by mail or e-mail as follows: CHANGES TO ALTEP’S SAFE HARBOR PRIVACY POLICY This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Altep will provide appropriate public notice about such amendments via its website (www.altep.com.) |
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