SAVO complies with the U.S- E.U. Safe Harbor Framework and the U.S.- Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union member countries and Switzerland. SAVO has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view SAVO’s certification, please visit http://www.export.gov/safeharbor/.
1. Web Sites Covered
SAVO’s Web sites may contain links to other Web sites. SAVO takes reasonable measures to ensure that the SAVO Web site is free of malware, but SAVO is not responsible for the information practices, content, or terms of service of such other Web sites. The Company encourages you to review the privacy policies of other Web sites to understand their information practices and terms of service.
2. Personally Identifiable Information Collected
SAVO offers a variety of services that are collectively referred to as the “Service.” SAVO collects information from individuals who simply visit the Company’s Web sites and/or who wish to obtain additional information about the Service (“Visitors”) and individuals registered to use the Service (“Customers”).
When expressing an interest in obtaining additional information about the Service or registering to use the Service, SAVO requires you to provide the Company with contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Service, SAVO requires you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Service (“Billing Information”). SAVO may also ask you to provide additional information, such as annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information and Optional Information are referred to collectively as “Data About SAVO Customers”.
As you navigate the Company’s Web site, SAVO may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type, browser version, and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked).
3. Use of Information Collected
The Company uses Data About SAVO Customers to perform requested Service, and for other internal product development efforts. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Service.
The Company may also use Data About SAVO Customers for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in SAVO, the Service, and to send you information regarding the Company and its partners, such as information about promotions or events.
SAVO uses credit card information solely to check the financial qualifications of prospective Customers and to collect payment for the Service.
SAVO uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information in combination with Data About SAVO Customers to provide Visitors and Customers with personalized information about the Company.
SAVO may link or combine Data About SAVO Customers and data about Visitors (including personally identifiable information) with information we get from other sources to help understand your needs and provide you with better service.
4. Web Site Navigational Information
SAVO collects Web Site Navigational Information as you navigate the Company’s Web sites. This section describes the types of Web Site Navigational Information the Company may collect, typical methods used for collection of such information, and how the Company may use this information.
There are two types of cookies: HTML (or browser) cookies and Flash cookies (also called Locally Stored Objects or LSOs). Flash cookies can hold more information that browser cookies and are more difficult to delete. SAVO’s Web sites do not use Flash cookies. The remainder of this section refers only to browser cookies.
There are two types of cookies: session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer.
If you have chosen to identify yourself to SAVO, the Company uses session cookies containing encrypted information to allow the Company to uniquely identify you. Each time you log into the Service, a session cookie containing an encrypted, unique identifier that is tied to your use of the Service is placed on your browser. These session cookies allow the Company to uniquely identify you when you are logged into the Service and to process your online transactions and requests. Session cookies are required to use the Service.
SAVO uses persistent cookies that only the Company can read and use to identify browsers that have previously visited the Company’s Web sites. When you purchase the Service or provide the Company with personally identifiable information, a unique identifier is assigned you. This unique identifier is associated with a persistent cookie that the Company places on your Web browser. The Company does not store account numbers or passwords in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate the Company’s Web sites, but you will not be able to successfully use the Service.
SAVO may use information from session and persistent cookies in combination with Data About SAVO Customers to provide you with information about the Company and the Service.
SAVO uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, SAVO may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. SAVO uses Web beacons to operate and improve the Company’s Web sites and email communications. SAVO may use information from Web beacons in combination with Data About SAVO Customers to provide you with information about the Company and the Service. SAVO does not use Web beacons to transfer personally identifiable information that is linked to sensitive information such as social security numbers, financial account and transaction information, or health information.
When you visit SAVO’s Web sites, the Company collects your IP addresses to track and aggregate non-personally identifiable information. For example, SAVO uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites.
SAVO also collects IP addresses from Customers when they log into the Service as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features.
Third Party Cookies
From time-to-time, SAVO engages third parties to track and analyze non-personally identifiable usage and volume statistical information from individuals who visit the Company’s Web sites. These third parties may place material on our Web sites, such as banner ads, that allow their servers to place cookies in your web browser. SAVO may also use other third-party cookies to track the performance of Company advertisements. The information provided to third parties by means of these third party cookies does not include personally identifiable information, but this information may be re-associated with personally identifiable information after the Company receives it. Users and Visitors may disable the ability of their web browsers to receive third party cookies without impairing their ability to use the Company’s Web sites.
Behavioral Targeting / Re-Targeting
5. Public Forums, Refer a Friend, and Customer Testimonials
SAVO may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personally identifiable information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. SAVO is not responsible in any respect for the personally identifiable information you choose to submit in these forums, and urges you not to submit any personally identifiable information to any such forum. To request removal of your personally identifiable information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personally identifiable information, in which case we will let you know if we are unable to do so and why.
Customers and Visitors may elect to use the Company’s referral service to inform friends about the Company’s Web sites. When using the referral service, the Company requests the friend’s name and email address. SAVO will automatically send the friend a one-time email inviting him or her to visit the Company’s Web sites. SAVO does not store this information.
SAVO posts a list of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. SAVO obtains the consent of each Customer prior to posting any information on such a list or posting testimonials within the log in to the client area. If you wish to update or delete your testimonial, you can contact us at email@example.com.
6. Sharing of Information Collected
SAVO may share Data About SAVO Customers and data about Visitors with the Company’s agents so that these agents can contact Customers and Visitors who have provided contact information on our behalf. SAVO may also share Data About SAVO Customers with the Company’s agents to ensure the quality of information provided.
SAVO may also share Data About SAVO Customers and data about Visitors with the Company’s third party partners who may use such information to communicate with you about products and services that we think will be of interest to you.
SAVO uses a third-party intermediary to manage credit card processing. This intermediary is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.
SAVO reserves the right to disclose personally identifiable information of the Company’s Customers or Visitors if: required by law; if the Company reasonably believes that disclosure is necessary to protect the Company’s rights; if necessary to perform credit checks or collect or report debts owed to us; and/or to comply with a judicial or other government subpoenas, warrants, court orders or other legal process (collectively, such laws, rights and proceedings, orders and processes are referred to below as “Legal Processes”).
SAVO may also share personally identifiable information of the Company’s Customers or Visitors with persons who perform certain services for us, such as our accountants, auditors, attorneys and the like, but only to the extent necessary for them to perform their services to us. We expect such service providers to comply with our privacy and information security standards.
7. Communications Preferences
SAVO offers customers and visitors who provide contact information a means to choose how SAVO uses the information provided. You may manage receipt of email communications from SAVO by clicking on the “ to manage your subscriptions or to unsubscribe, click here” link located on the bottom of the SAVO’s emails. Additionally, you may send a request specifying your communications preferences to firstname.lastname@example.org. If you no longer wish to allow us to share your information with third parties, you may opt-out from such sharing by contacting that third party directly.
8. Correcting and Updating Your Information
SAVO is committed to ensuring that the personally identifiable information that it collects in the client area regarding its Customers and Visitors is reliable for its intended uses and is accurate, complete, and current. If SAVO discovers that corrections are necessary with respect to any such information, it promptly updates its records. Customers may also update or change their registration information by editing their user or organization record. To update a user profile or billing information, please email email@example.com or call (312) 506-1700. Requests to access, change, or delete your information will be handled within 90 days. We will respond to your access request within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us as described below. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. Customer Data
SAVO Customers use the Service to host data and information (“Customer Data”). SAVO will not review, share, distribute, or reference any such Customer Data except as provided in the SAVO Application Services Agreement (or similar services agreement), or as may be required by Legal Processes, and will host Customer Data solely to facilitate the processing and use of the Customer Data by its Customers. Individual records of Customer Data may be viewed or accessed by SAVO only for the purpose of resolving a problem, support issues, or suspected violation of the SAVO Application Services Agreement, or as may be required by Legal Processes. Customers are responsible for maintaining the security and confidentiality of their SAVO usernames and passwords. Customers maintaining Customer Data that constitutes personally identifiable information subject to the protections of the European Union’s Data Protection Directive will remain responsible for such information vis-à-vis the individual in accordance with the relevant EU provisions, although, as set forth in the SAVO Application Services Agreement, SAVO will cooperate with the Customer as may be necessary to ensure that individuals’ rights to access and correct such information are respected. SAVO permanently deletes or destroys Customer Data residing on its servers promptly upon the termination of a Customer relationship.
Information Related to Data Collected for our Clients
SAVO collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Access and Retention of Data Controlled by our Clients
SAVO has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to SAVO’s Client (the data controller). If the Client requests SAVO to remove the data, we will respond to their request within 30 days.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. SAVO will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
SAVO uses industry standard security measures to protect Customer Data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Customer Data. The Service can be accessed only by Internet Explorer version 6.0 or later, Firefox version 2.0 or later, or Safari version 3.0 or later, because these browsers permit the use of Transport Layer Security (“TLS”) technology (formerly Secure Socket Layer or SSL technology) that protects Customer Data using both server authentication and data encryption. These technologies help ensure that Customer Data is safe, secure, and only available to the Customer to whom the information belongs and those to whom the Customer has granted access. SAVO also implements an advanced security method based on dynamic data and encoded session identifications, and the Company hosts its Web sites in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders. SAVO also offers enhanced security features within the Service that permit Customers to configure security settings to the level they deem necessary.
11. Social Media Widgets
13. Contacting Us
If you have any complaints regarding our compliance with the Safe Harbor you should first contact us (as provided above). If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet here, fax to 415-520-3420, or mail to TRUSTe Safe Harbor Compliance Dept., click for mailing address. 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 complaint shared with the company. For information about TRUSTe or the operation of TRUSTe’s dispute resolution process, click here or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English. For human resources data we have agreed to cooperate with Data Protection Authorities.
14. Your California Privacy Rights
Under California’s Shine the Light law, Cal. Civ. Code § 1798.83, California residents have the right under certain circumstances to request, once per year, information regarding our disclosure of personal information to third parties for direct marketing purposes, including a list of the categories of information we have shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. To make such a request, please contact us by emailing firstname.lastname@example.org or by mailing SAVO Privacy and Security, 155 N. Wacker Dr., Suite 1000, Chicago, IL 60606.