PRIVACY POLICY
Introduction: Electronic Marketing Solutions and its
subsidiaries around the world (collectively, “Electronic Marketing Solutions”)
are committed to respecting and protecting the privacy of those from whom they
collect personal information.
Policy: This policy establishes and communicates the key
principles Electronic Marketing Solutions follows in protecting the personal
information that it collects. Please note that some privacy rights and
obligations may differ in certain locations based on local law, in which case
Electronic Marketing Solutions will comply with the local legal requirements.
Definitions: Data Subject is any individual about whom
Electronic Marketing Solutions holds personal data. Personal data is any
information that allows an individual to be identified directly or indirectly
(e.g., name, date of birth, title, address, telephone number and email
address). Sensitive personal data is that which, in cases of misuse, may cause
unlawful or arbitrary discrimination or other serious risk to a data subject
(e.g., racial or ethnic origin, nationality, political opinion, religious and
philosophical beliefs, and physical or mental health conditions). Collectively,
personal data and sensitive personal data are referred to as “personal
information.”
Collecting and Processing Personal Information: Electronic
Marketing Solutions collects and processes personal information that is
necessary for legitimate business purposes, which will be disclosed to the data
subject at the time of collection. Electronic Marketing Solutions will use and process this information only
for the purposes for which it was collected, retaining the personal information
only for so long as is required for the specific purpose for which the
information was collected.
Electronic Marketing Solutions will not collect sensitive
personal data except when permitted or required to do so by law, and will do so
only for legitimate business purposes. If in any other instance a need arises
to collect sensitive personal data, Electronic Marketing Solutions will do so
only with the data subject’s express consent, which can be withdrawn at any
time. Electronic Marketing Solutions will not sell or rent personal information
for direct marketing purposes.
Colleague Obligations: When part of their job
responsibilities, colleagues who collect and process personal information must
comply with this policy and any applicable data protection procedures. In
particular, they must: Ensure the personal information is collected and processed
in accordance with this policy; Check that the personal information provided is
accurate and up to date; Ensure timely updates to related internal company
files; Check the information Electronic Marketing Solutions distributes and provide details regarding
processing notices on relevant communications; and take reasonable precautions
to protect the personal information from unauthorized disclosure, loss, or
destruction.
Colleague Obligations: When part of their job
responsibilities, colleagues who collect and process personal information must
comply with this policy and any applicable data protection procedures. In
particular, they must: Ensure the personal information is collected and
processed in accordance with this policy; Check that the personal information
provided is accurate and up to date; Ensure timely updates to related internal
company files; Check the information Electronic Marketing Solutions distributes and provide details regarding
processing notices on relevant communications; and take reasonable precautions
to protect the personal information from unauthorized disclosure, loss, or
destruction.
Transferring Personal Information: Electronic Marketing
Solutions may transfer the personal information outside the data subject’s home
country when: (i) it has the consent of the data subject; (ii) it is necessary
or appropriate as permitted by law to do so because it is relevant to
Electronic Marketing Solution’s dealings with the data subject; or (iii) it is
required by law. Electronic Marketing Solutions will comply with notification,
registration or approval requirements imposed under local law regarding the
cross border transfer of personal information. Electronic Marketing Solutions
will implement reasonable measures to protect the security and confidentiality
of personal information and provide an adequate level of protection in each
Electronic Marketing Solutions location where the information is transferred.
Onward Transfer: In limited circumstances, Electronic
Marketing Solutions may disclose personal information to a third party who is
providing a service to Electronic Marketing Solutions. Electronic Marketing
Solutions will only disclose personal information if the third party has
provided satisfactory assurances to Electronic Marketing Solutions of its
ability to provide appropriate and sufficient data privacy and security
safeguards to protect the personal information from unauthorized disclosure,
use or loss. Where Electronic Marketing Solutions learns that a third party is
using or disclosing personal information in a manner contrary to this policy,
Electronic Marketing Solutions will take reasonable steps to discontinue such
use or disclosure. Disclosures to third parties will be only for the purposes
described in this policy, for a compatible purpose, or for a purpose authorized
by the data subject.
Choice: Electronic Marketing Solutions gives data subjects
the opportunity to choose not to have his or her personal information
transferred to third parties for use in a manner incompatible with the purpose
for which it was originally collected. An employee may not opt out of the
transfer of his or her personal information to a third party if it is being
conducted for the purpose of: (1) meeting applicable legal requirements, or (2)
furthering the legitimate employment relationship with Electronic Marketing
Solutions. Prior to transferring sensitive personal data for use in a manner
incompatible with the purpose for which it was originally collected, explicit
(opt in) choice will be sought.
Security of Personal Information: Electronic Marketing
Solutions has organizational, physical, administrative and technical measures
in place to protect the personal information the company collects and
maintains. Electronic Marketing Solutions monitors to ensure that its
information security program is operating in a manner to reasonably protect the
personal information it collects and processes and upgrades information
safeguards as necessary to limit risks of unauthorized disclosure or use. Only
authorized colleagues with a valid, work-related need may access a data
subject’s personal information. In the event of a data breach, Electronic
Marketing Solutions will issue breach notifications as may be required under
applicable law.
Data Subject Rights: While personal information is
maintained by Electronic Marketing Solutions, a data subject may access the
information pertaining to him/her to the extent required by local law to
review, update and correct inaccuracies. To do so, the data subject should contact
the Electronic Marketing Solutions Global Privacy Officer or the Privacy
Officer in the data subject’s home country (if one has been appointed).
Additionally, a data subject may ask Electronic Marketing Solutions to correct,
update, supplement or delete personal information held on him/her. Electronic
Marketing Solutions may, in its discretion, charge a reasonable, cost-based fee
for access or photocopying of this information. For security purposes,
Electronic Marketing Solutions may require verification of identity before
providing access to personal information.
Responsibility: If a data subject has a question about this
policy or a complaint about the way Electronic Marketing Solutions has collected, processed, used or disclosed
his/her personal information and is located in Germany, the data subject should
contact his or her local Privacy Officer. Data subjects located in any other
country should contact the Electronic Marketing Solutions Global Privacy
Officer. Both individuals will promptly and courteously address any complaints
or disputes regarding personal information. Electronic Marketing Solution’s
Privacy Officers have the responsibility to ensure that each Electronic
Marketing Solutions office complies with this policy around the world. It is
also the responsibility of these persons to deal with and respond to all
inquiries from governmental authorities. Any finding of misuse of personal
information by Electronic Marketing Solutions or a breach of this policy shall
be remedied as soon as reasonably possible.
Verification: To verify its compliance Electronic Marketing
Solutions will periodically conduct a
self-assessment to ensure that: (a) this policy is accurate, comprehensive,
prominently displayed, completely implemented and accessible, and conforms to
the Safe Harbor Principles; (b) employees are informed of the internal
arrangements for handling complaints and the independent mechanisms through
which they may pursue complaints; and (c) Electronic Marketing Solutions has in place procedures for training the
appropriate employees on the implementation of this policy and disciplining
those who fail to comply.
Changes to this Policy: Electronic Marketing Solutions may
revise this policy at any time and will post any revised Personal Information
Privacy Policy to www.ElectronicMarketing.Solutions
Contact information for the Electronic Marketing Solutions
Privacy Officer is as follows:
Electronic Marketing Solutions
Attn: Global Privacy Officer
5000 Birch St, Suite 3000, Newport Beach, CA 92660
Privacy@ElectronicMarketing.Solutions