Company Policy POL/GLO/05
Revision Date / Status: Feb. 04, 2014 / R-03
This document provides guidance regarding the protection of Personal Data that may be transferred globally by syncreon Global Holdings Limited and any of its subsidiary and affiliate companies (collectively the “Company”).
EVP – CIO, Julian Mordaunt
EVP – HR, Annette Cyr
|Actively Involved:||General Counsel – Kenneth Pocius|
The Company respects individual privacy and values the confidence of our customers, employees, suppliers, independent contractors, consultants, business partners, and others. The Company adheres to the Safe Harbor Principals concerning the transfer of Personal Data from the European Union or ‘Commonwealth’ to the United States of America. Accordingly, we follow the Safe Harbor Principles with respect to the transfer of personal data between any and all countries. This policy outlines the Company’s general policy and practices for implementing the Safe Harbor Privacy Principles, including the types of information the company gathers, how we use it, and the choices the affected individuals have regarding our use of, and their ability to correct, that information.
This policy applies to all Personal Information or Sensitive Personal Data the Company handles, including on-line (except as noted below), off-line, and manually processed data.
Principles Protecting Individuals' Privacy Notice and Choice
To the extent permitted by the Safe Harbor Principles, we reserve the right to process Personal Information in the course of our internal business operation without the knowledge of individuals involved in a secure and protected method.
Where the Company receives Personal Information from its subsidiaries, affiliates, or other entities in the EU or any other country, the Company will use and disclose such information in accordance with the purposes for which it was originally collected, or in accordance with the notices provided by such entities.
The Company will provide notice and provide individuals with an opportunity to "opt-out" if such Personal Information is to be disclosed to a third party or used for a purpose incompatible with the purpose for which it was originally collected. For Sensitive Personal Data, affirmative or explicit, the Company will provide notice and individual choice will be given to "opt-in" if such Sensitive Personal Data is to be disclosed to a third party or used for a purpose other than the purpose for which it was originally collected.
The Company collects Personal Information from individuals only as permitted by the Principles or with the consent of the individual affected. Consent for Personal Information to be collected, used, and/or disclosed in certain ways may be required in order for an individual to obtain or use our services.
Disclosures and Transfers
The Company does not disclose an individual's Personal Information to third parties, except when one or more of the following conditions is true:
• is subject to law providing an adequate level of privacy protection;
• has agreed in writing to provide an adequate level of privacy protection; or
• subscribes to the Safe Harbor Privacy Principles.
Permitted transfers of information, either to third parties or within or between subsidiaries of the Company, including 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 standards for protection no less stringent than the jurisdiction in which the Personal Information originated.
Data Security, Integrity and Access
The Company will take all reasonable measures to ensure the protection of Personal Information from accidental loss, destruction, improper use, alteration, or disclosure. The Company processes Personal Information only in ways compatible with the purpose for which it was collected and authorized by the individual, if applicable. To the extent necessary for such purposes, the Company takes reasonable steps to make sure that Personal Information is accurate, complete, current, and otherwise reliable with regard to its intended use.
If an individual determines that the information the Company maintains about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may contact the Company using the contact information below. The individual will need to provide sufficient identifying information. We may request additional identifying information as a security precaution. In addition, the Company 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 Agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to Personal Information.
Collection of Information from Minors
The Company does not collect any information on any individuals who are below the age of 13 except where mandated by law.
“Cookie” may also be called an HTTP-, web-, or browser cookie and refers to data that is sent from a website and stored by the user’s browser. When the user returns to the website at a later date, the cookie can be used by the website to obtain information about the user’s previous activity on the website.
The Company does not collect any financial payments or financial information on the Company’s public website. Financial information that is collected by the Company by other means is secured in accordance with requirements of the customer contract.
The Company retains customer information for the period specified in the contracts with specific customers. When no longer required, customer information is destroyed in accordance with the requirements of the contract or applicable law.
We are committed to ensuring the privacy of the data you entrust us with. If you have any concerns regarding data or privacy you can contact us, alternatively you can raise your concerns with eTrust. They are a trusted third party who works with us to improve our privacy and data procedures. You can contact eTrust through this link:
In the event of a merger, all data will be transferred to the new entity
In the unlikely event of a bankruptcy proceeding, all information would be transferred in accordance with Court Order
Limitation on Application of Principles
Adherence by the Company to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation.
How to Contact Us
Should there be any questions or suggestions about the Company’s privacy practices, or wish to update or correct any personally identifiable information provided to the Company, please feel free to contact the Company
via email at dataprivacysyncreon.com
or telephonically at +1-248-475-6227
or by post at the following mailing address:
2851 High Meadow Circle, Suite 250
Auburn Hills, MI 48326 USA.
In accordance with our commitment to protect personal privacy, the Company adheres to the principles of the Safe Harbor Framework as developed by the U.S. Department of Commerce in consultation with the European Commission. The seven principles and fifteen Frequently Asked Questions (FAQs) referred to in this policy constitute Safe Harbor privacy framework. These principles and FAQs may be found at: http://www.export.gov/safeharbor