PRIVACY POLICIES FOR ITS PARTNERS, LLC
ITS PARTNERS, LLC Safe Harbor Data Privacy Statement
ITS Partners, LLC (“ITS”) is a national professional services firm providing endpoint management, IT automation and IT security solutions. Protecting your privacy is important to ITS. ITS and its affiliated U.S. subsidiaries (“the firm,” “we,” “us,” or “our”) complies with the U.S.-European Union (“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. ITS has certified that it adheres to the Safe Harbor Privacy Principles (“the Principles”) of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view ITS’s certification, please visit http://www.export.gov/safeharbor/. If there is any conflict between the policies in this statement and the Principles, the Principles will govern. This statement outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it, and the choices affected individuals have regarding our use of, and their ability to correct, that information.
This statement applies to all personal information we handle (except as noted below), including on-line, off-line, and manually processed data. For purposes of this statement, “personal information” means information that:
- is transferred from the EU to the United States;
- is recorded in any form;
- is about, or pertains to, a specific individual; and
- can be linked to that individual.
It does not include information that pertains to a specific individual, but from which that individual could not reasonably be identified.
Principles Protecting Individuals’ Privacy
Notice and Choice
To the extent permitted by the Safe Harbor Agreement, we reserve the right to process personal information in the course of providing professional services to our clients without the knowledge of individuals involved. Where we collect personal information directly from individuals in the EU and/or Switzerland, we inform them about the types of personal information we collect from them, the purposes for which we collect and use it, and the types of non-agent third parties to which we disclose that information. We also inform those individuals about the choices and means, if any, we offer individuals for limiting the use or disclosure of their information.
Disclosures and Transfers
ITS will not disclose an individual’s personal information to third parties, except when one or more of the following conditions is true:
- We have the individual’s permission to make the disclosure;
- The disclosure is required by law or professional standards;
- The disclosure is reasonably related to the sale or disposition of all or part of our business;
- The information in question is publicly available;
- The disclosure is reasonably necessary for the establishment or defense of legal claims; or
- The disclosure is to another ITS entity or to persons or entities providing services on our or the individual’s behalf (each a “transferee”), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
- 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 Principles.
Permitted transfers of information, either to third parties or within ITS, 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.
ITS takes your security seriously and takes reasonable steps to protect your information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of our clients, ITS has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we process. However, we cannot guarantee the security of information on or transmitted via the Internet.
We process 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, we take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.
Access and Correction
If an individual becomes aware that information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may contact us using the contact information below. We 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, birth date, and social security number. We may request additional identifying information as a security precaution. In addition, we 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.
Enforcement and Dispute Resolution
ITS utilizes the self-assessment approach to assure its compliance with our privacy statement. ITS 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. We encourage interested persons to raise any concerns with us using the contact information below. We 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.
With respect to any complaints relating to this policy that cannot be resolved through our internal processes, we have agreed to participate in the dispute resolution procedures of the panel established by the competent EU or Swiss data protection authorities to resolve disputes pursuant to the Safe Harbor Principles. In the event that we or such authorities determine that we did not comply with this policy, we will take appropriate steps to address any adverse effects and to promote future compliance.
Any person who we determine is in violation of our privacy policies will be subject to disciplinary process.
Privacy Statement Changes
This privacy statement may be changed from time to time, consistent with the requirements of the Safe Harbor. We will post any revised policy on this Web site, or a similar Web site that replaces this Web site.
Information Subject to Other Policies
We are committed to following the Principles for all personal information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of the firm that may differ in some respects from the general policies set forth in this statement.
- Information obtained from or relating to clients or former clients is further subject to the terms of any privacy notice to the client, any engagement letter or letters with the client, and applicable laws and professional standards.
How to Contact Us
Questions, comments or complaints about ITS’s Safe Harbor Data Privacy Statement or data collection and processing practices can be e-mailed to privacy@ITS.com, mailed to Privacy Officer, ITS Partners, LLC, 4079 Park East Court, Grand Rapids, MI 49546. In the event that a complaint is not satisfactorily addressed by ITS within a reasonable time frame, you may contact the Federal Trade Commission at www.ftc.gov/ftc/complaint.htm, or via phone at 202-382-4357.
EFFECTIVE DATE: April 15, 2015.
ITS respects your privacy and is committed to protect the personal information that you share with us. Generally, you can browse through our website without giving us any information about yourself. When we do need your personal information to provide services that you request or when you choose to provide us with your personal information, this policy describes how we collect and use your personal information.
Personal information means any information that may be used to identify an individual, including, but not limited to, a first and last name, email address, a home, postal or other physical address, other contact information, title, birth date, gender, occupation, industry, personal interests, other information when needed to provide a service you requested.
When you browse our website, you do so anonymously, unless you have previously indicated that you wish ITS to remember your login and password. We don’t automatically collect personal information, including your email address. We do log your IP address (the Internet address of your computer) to give us an idea of which part of our website you visit and how long you spend there. But we do not link your IP address to any personal information unless you have logged in to our website. Like many other commercial websites, the ITS website may use a standard technology called a “cookie” to collect information about how you use the site. Please go to “Cookies and Tracking Information” below for more information.
ITS collects personal information when you register with ITS for a ITS account, when you use certain ITS products or services, when you register to attend a seminar or participate in an online survey, when you ask to be included in an email or other mailing list, or you submit an entry for a sweepstakes or other promotions, or when you submit your personal information to ITS for any other reason. From time to time, ITS receives personal information from business partners and vendors. ITS only uses such information if it has been collected in accordance with acceptable privacy practices consistent with this Policy and applicable laws.
Access to certain ITS web pages require a login and a password. The use of those web pages, and the information or programs downloadable from those sites, may be governed by a written agreement between your employer and ITS. Unless you request deletion of your personal information as specified below, your personal information may be retained by ITS to verify compliance with the agreement, log software licenses granted, to track software downloaded from those pages, or track usage of other applications available on those pages.
When personal information is collected, we will inform you at the point of collection the purpose for the collection. ITS will not transfer your personal information to third parties without your consent, except under the limited conditions described under the discussion entitled “Information Sharing and Disclosure” below.
If you choose to provide us with your personal information, we may only transfer that information, within ITS or to ITS’s third party service providers with your permission. Upon receiving your permission, we may transfer your information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
We will always give you the opportunity to “opt out” of receiving direct marketing or market research information. This means we assume you have given us your consent to collect and use your information in accordance with this Policy unless you take affirmative action to indicate that you do not consent, for instance by clicking or checking the appropriate option or box at the point of collection. In some cases, when applicable, we will provide you with the opportunity to “opt in.” This means we will require your affirmative action to indicate your consent before we use your information for purposes other than the purpose for which it was submitted.
Cookies and Tracking Technology
If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of ITS’s website if you do so. In particular, you may be required to accept cookies in order to complete certain actions on our website. You do not need to have cookies turned on, however, to use/navigate through many parts of our website, except access to certain of ITS’s web pages may require a login and password.
How We Use Information Collected
ITS uses information for several general purposes: to fulfill your requests for certain products and services, to personalize your experience on our website, to keep you up to date on the latest product announcements, software updates, special offers or other information we think you’d like to hear about either from us or from our business partners, and to better understand your needs and provide you with better services. We may also use your information to send you, or to have our business partners send you, direct marketing information or contact you for market research.
Information Sharing and Disclosure
Your personal information is never shared outside ITS without your permission, except under conditions explained below. Inside ITS, data is stored in controlled servers with limited access. Your information may be stored and processed in the United States or any other country where ITS, its subsidiaries, affiliates or agents are located.
Your ITS account information is password-protected for your privacy and security. ITS safeguards the security of the data you send us with physical, electronic, and managerial procedures. In certain areas of our websites, ITS uses industry-standard SSL-encryption to enhance the security of data transmissions. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to us, and so we urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser.
Children and Privacy
Our websites do not target and are not intended to attract children under the age of 13. ITS does not knowingly solicit information from children under the age of 13 or send requests for information.
Third Party Sites
ITS’ website contains links to other sites. ITS does not share your personal information with those websites and is not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies.
ITS will amend this policy from time to time. If we make any substantial changes in the way we use your personal information we will make that information available by posting a notice on this site.
Questions or Suggestions
If you have questions or concerns about our collection, use, or disclosure of your personal information, please email us at firstname.lastname@example.org.