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, Platforms and Mobile Application Covered
SAVO’s Digital Properties may contain links to other web sites. SAVO takes reasonable measures to ensure that SAVO’s Digital Properties 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 Digital Properties 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 Digital Properties, SAVO may also collect information through the use of commonly-used tracking technologies, 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 Digital Properties (such as the web pages viewed and the links clicked). For more information, please see Section 4 Web Site Navigational Information below.
When you download and use our Services, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID”).
We do not ask you for, access or track any location based information from your mobile device at any time while downloading or using our mobile application or Services.
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 Digital Properties. 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.
4. Web Site Navigational Information
SAVO collects Web Site Navigational Information as you navigate the Company’s Digital Properties. 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.
Technologies such as: cookies, beacons, tags, and scripts are used by SAVO and our third party partners such as our marketing partners, analytics, and customer support service providers. These technologies are used to make interactions with the Company’s Digital Properties easy and meaningful. We also use technologies for analyzing trends, administering the site, tracking users’ movements around these properties and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. SAVO uses this information for various purposes such as tracking and monitoring Customers and Visitors activities on Company’s Digital Properties. For example, SAVO uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Digital Properties and to authenticate Customers credential as part of its security features. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, and site functionality.
Behavioral Targeting / Re-Targeting
We use Local Storage Objects (LSOs) such as Flash and HTML 5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as Flash and HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML 5 LSOs. To manage Flash LSOs, please click here.
5. Public Forums, Refer a Friend, and Customer Testimonials
SAVO may provide blog or forum on the Company’s Digital Properties. 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 may elect to use the Company’s referral service to inform friends about the Company’s Digital Properties. 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 Digital Properties. SAVO does not store this information.
SAVO posts testimonials on the Company’s Digital Properties 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, protect your safety or the safety of others, and to investigate fraud; 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 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 will promptly update 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. Visitors may update or change their personal information by clicking here. 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 8.0 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 SAVO Digital Properties 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.
Although we strive to make security a priority, note that no method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Company’s Digital Properties, you can contact firstname.lastname@example.org.
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, 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 email@example.com or by mailing SAVO Privacy and Security, 155 N. Wacker Dr., Suite 1000, Chicago, IL 60606.