Exterro respects individual privacy and values the confidence of its customers, their stakeholders, employees, business partners, and others who may use their services. Not only does Exterro strive to operate in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in their business practices. This Safe Harbor Policy sets forth the privacy principles that Exterro follows with respect to the protection and transfers of personal information from the European Economic Area (EEA) and from Switzerland to the United States.
We do not collect any personal information (name, address, telephone number, or e-mail address) unless you provide it. We may request this information when a product or demo is downloaded, for newsletter subscriptions, or when additional information about our products or services is requested.
If you have submitted personal information and want it removed from our records, please contact us at the e-mail address listed at the bottom of this Privacy Statement.
The following privacy principles are based on the Safe Harbor Framework.
Notice and Choice To the extent permitted by the Safe Harbor Framework, Exterro reserves the right to process personal information in the course of providing professional services to their clients without the knowledge of individuals involved. Where Exterro collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which Exterro discloses that information, the choices and means, if any, Exterro offers individuals for limiting the use and disclosure of personal information about them, and how to contact Exterro.
Where Exterro receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates. Data Integrity Exterro processes personal information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, Exterro takes reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.
Protecting Exterro will not disclose an individual's personal information to third parties, except when one or more of the following conditions is true:
Permitted transfers of information, either to third parties or within Exterro, include the transfer of data from one jurisdiction to another, including transfers to and from the United States of America. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated. Exterro complies with the U.S.-EU 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 information from European Union member countries and Switzerland. Exterro 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 Exterro' certification, please visit http://www.export.gov/safeharbor/
Exterro will take reasonable precautions to protect personal information in its possession from loss, misuse, unauthorized access, disclosure, alteration, destruction; and ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of their clients. Exterro has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information it processes. However, Exterro cannot guarantee the security of information on or transmitted via the Internet or a third party software tool.
If an individual becomes aware that information Exterro maintains about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may contact Exterro using the contact information below. Exterro will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate. The individual will need to provide sufficient identifying information, such as name, address, birthdate, and social security number. Exterro may request additional identifying information as a security precaution. In addition, Exterro may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Framework. In some circumstances, Exterro may charge a reasonable fee, where warranted, for access to personal information.
Exterro utilizes the self-assessment approach to assure its compliance with this privacy statement. Exterro periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the principles. Exterro encourages interested persons to raise any concerns with us using the contact information below. Exterro will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy. Exterro has established a Safe Harbor team composed of senior members from Human Resources, Operations, Privacy, and Legal. The team will undertake self-assessment with an independent third party, as needed to ensure compliance to the Safe Harbor Principles. All requests or complaints may be submitted via email to firstname.lastname@example.org or via mail at the address listed below. Once any request or complaint affecting these Principles has been submitted to Exterro the Safe Harbor team will promptly notify the data subject that the request or complaint has been received and is being investigated. The Team will notify each data subject regarding the resolution of their request or complaint. For complaints that cannot be resolved between Exterro and the complainant, Exterro has agreed to participate in the following dispute resolution procedures of the Judicial Arbitration and Mediation Services (JAMS) in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Framework. Exterro commits to cooperating fully with EU Data Protection Authorities and the Swiss Federal Data Protection and Information Commission.
Exterro will conduct compliance audits of its relevant privacy practices to verify adherence to this policy. Any employee that Exterro determines is in violation of this policy or other company privacy policies will be subject to disciplinary action up to and including termination of employment.
Adherence by Exterro to these Safe Harbor Principles in the Safe Harbor Framework may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
Questions or comments regarding Exterro' Safe Harbor certification should be submitted to Exterro by mail or e-mail as follows:
Office of the General Counsel 4145 SW Watson Suite 400 Beaverton, OR 97005 USA legal@Exterro.com