2 Guiding Principles
2.2 SourceHOV expects employees, independent contractors, vendors and other users of systems and documents that may contain personal information to protect such personal information from unauthorized disclosure or use; and destroy or delete such personal information when no longer required for the purpose intended or by law, whichever is longer.
2.3 SourceHOV expects each employee, independent contractor, vendor or other user of personal information to apply appropriate measures to protect personal information where collected, used or stored in accordance with the applicable and enforceable laws of those countries in which SourceHOV is operating. As global laws and ethical concerns of privacy are constantly evolving, SourceHOV will continue to adopt reasonable policies and information security measures to meet these evolving standards.
3.1 SourceHOV adheres to the U.S.-E.U. Safe Harbor privacy policies of Notice, Choice, Onward Transfer, Security, Data Integrity and Access and Enforcement.
3.2 Collection of Information. SourceHOV collects personally identifiable information when voluntarily submitted by our online and on site visitors. The information provided is used to fulfill specific requests. This information is only used to fulfill the specific request, unless given permission to use it in another manner. In order to provide our full range of services, Source HOV may collect the following types of information:
3.2.1 Personally Identifiable Information (PII). This includes names, postal addresses, email addresses, phone numbers, company information, etc., as provided by SourceHOV' clients and website visitors.
3.2.3 User Communications. When a visitor sends an email or other communication to SourceHOV, SourceHOV may retain those communications in order to process inquires, respond to requests, and improve our overall services.
3.2.4 Affiliated Sites. SourceHOV offers some of its services in connection with other websites. Personal information that a visitor provides to those sites may be sent to SourceHOV in order to deliver the service. SourceHOV processes such information in accordance with this Policy. The affiliated sites may have different privacy practices and policies and SourceHOV encourages all visitors to read and familiarize themselves with the affiliated company's privacy policies.
3.3 Notice and Choice. To the extent permitted by the Safe Harbor Agreement, SourceHOV reserves the right to process personal information in the course of providing professional services to our clients without the knowledge of individuals involved. Where SourceHOV collects personal information directly from individuals in the European Union, SourceHOV will inform them about the types of personal information SourceHOV collects from them, the purposes for which SourceHOV collects and uses such information, and the types of non-agent third parties to which SourceHOV discloses that information. SourceHOV will also inform those individuals about the choices and means, if any, SourceHOV offers individuals for limiting the use or disclosure of their information.
3.4 Disclosure and Transfers. In general, SourceHOV will not disclose any of a visitor's personally identifiable information except when HOV Services has a visitor's permission under special circumstances, such as when SourceHOV believes in good faith that the law requires it or under other circumstances outlined in this Policy. SourceHOV may share information with governmental agencies or other companies assisting SourceHOV.
3.4.1 SourceHOV may share information with governmental agencies or other companies assisting SourceHOV in fraud prevention or investigation. SourceHOV may do so when: (1) permitted or required by law; or, (2) trying to protect against or prevent actual or potential fraud or unauthorized transactions; or, (3) investigating fraud which has already taken place. The information is not provided to these companies for marketing purposes.
3.4.2 Permitted transfers of information, either to third parties or within SourceHOV, 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 personal information originated.
3.5 Data Security. SourceHOV takes reasonable steps to protect all personally identifiable information that we handle. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of personally identifiable information, either for its own purposes or on behalf of our clients, SourceHOV has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal information we possess. However, SourceHOV cannot guarantee the security of personally identifiable information on or transmitted via the Internet.
3.6 Data Integrity. SourceHOV possesses personally identifiable 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, we take reasonable steps to make sure that personal information is accurate, complete, current and otherwise reliable with regard to its intended use.
3.7 Access and Correction. If an individual becomes aware that personally identifiable information SourceHOV maintains about that individual is inaccurate, or if an individual would like to update or review his or her personal information, the individual may contact SourceHOV using the contact information below.
3.7.1 SourceHOV will take reasonable steps to permit individuals to correct, amend, or delete personally identifiable information that is demonstrated to be inaccurate. The individual will need to provide sufficient identifying personal information, such as name, address, birth date, and social security number. SourceHOV may request additional identifying personal information as a security precaution.
3.7.2 SourceHOV may limit or deny access to personally identifiable 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, SourceHOV may charge a reasonable fee, where warranted, for access to personally identifiable information.
3.8.1 SourceHOV periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Safe Harbor Principles.
3.8.2 SourceHOV encourages interested persons to raise any concerns with us using the contact information below. SourceHOV 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.
3.8.3 With respect to any complaints relating to this Policy that cannot be resolved through our internal processes, SourceHOV has agreed to participate in the dispute resolution procedures of the panel established by the European Union Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles.
3.8.4 If SourceHOV or the European Union Data Protection Authorities determine that SourceHOV did not comply with this Policy, SourceHOV will take appropriate steps to address any adverse effects and to promote future compliance.
3.9 Sale of Assets, Merger or Acquisition. In the event SourceHOV merges, is acquired by or sells its assets to a third party, SourceHOV may disclose personally identifiable information as is reasonably necessary to affect any such merger, acquisition or sale. Individuals will be afforded the opportunity to opt-out of the SourceHOV offering consistent with our opt-out provisions.
3.9.1 Any such party with whom SourceHOV merges or whom acquires some or all of the assets of SourceHOV may not have the same or similar privacy guidelines as set forth in this Policy and may use personally identifiable information in a manner other than as set forth herein.
3.10 This Policy may be changed from time to time, consistent with the requirements of the Safe Harbor Agreement. SourceHOV will post any revised Policy on its website, or a similar site that replaces that site.
3.11 Certain information is subject to SourceHOV policies that may differ in some respects from the general policies set forth in this statement.
3.12 Information obtained from or relating to clients or former clients is further subject to the terms of any privacy notice to the client, any contract or other agreement with the client, and applicable and enforceable laws.
3.14 Formal written complaints should be sent to the attention of the Privacy Official at 1305 Stephenson Highway, Troy, Michigan 48083.
3.16 SourceHOV will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between SourceHOV and an individual.
3.17 If a complaint is not satisfactorily addressed by SourceHOV within a reasonable time frame, you may contact the Federal Trade Commission at https://www.ftccomplaintassistant.gov/, or via phone at 1.877.382.4317.
4.1 "Visitor" shall mean any individual or business, which visits the SourceHOV website. This term may have been used synonymously with the term "individual" throughout this Policy.