Protection of personal data policy
Version of 06th December 2011
Neolane has drawn up this confidentiality policy (the “Policy”) to show its commitment to protecting the following personal information:
- Personal information that may be provided by visitors (“Visitors”) using its Website www.neolane.com (“Website”);
- Personal information on customers (“Users”) using Neolane’s software program (“Program”);
- Personal information concerning customers and prospects of Users of the Program (“Contacts”) when this information is handled by Neolane’s servers when said Program is used in hosted mode.
Neolane is responsible for personal information concerning Visitors and Users. Neolane’s rules and practices concerning the collection, use, storage and disclosure of such information are detailed in the first section of this Policy. The second section concerns the personal information of Contacts, for which the User is responsible.
I. Protection of information provided by Visitors and Users
International Transfers/Safe Harbor Program
We self-certify compliance with
Neolane 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. Neolane 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 Neolane’s certification, please visit: http://www.export.gov/safeharbor/.
Neolane’s servers are currently located in Europe and the United States. To satisfy the requirements of appropriate protection of data transferred from the European Union to the United States, Neolane Inc. has officially joined the Safe Harbor program managed by the United States Department of Commerce. Neolane Inc. complies with the principles of Safe Harbor for the collection, use and storage of personal data coming from the European Union. To access Neolane’s certification document, click on the following link: http://safeharbor.export.gov/list.aspx. For more information on the Safe Harbor program, visit http://www.export.gov/safeharbor/.
Data collected by Neolane
Visitors to the Website may register and provide personal information in certain circumstances: particularly when they download the information brochure, subscribe to newsletters, sign up for events; or more generally when they access a section of the website requiring registration. This personal data may include their first name, last name, e-mail address or any other information allowing Visitors to be contacted. This information is provided voluntarily. Visitors can choose not to provide any personal information, however cannot in this case benefit from all the services offered by the Website.
Neolane guarantees Visitors that the collection and handling of personal data from the Website is carried out in accordance with current legislation.
Use of information collected/Purpose of handling
The information collected by Neolane is registered in the Neolane database. This way, Visitors will be able to benefit from the services they are offered on the Website (information/documentation requests, signing up for an event) and their right to access certain areas of the website can be verified. This information is for corporate professional use only within the context of relations between corporate professionals.
Integrity and confidentiality of data
Neolane will take all commercially reasonable precautions necessary to protect the the confidentiality and integrity of the personal data of Visitors and Users and, in particular, to prevent it from being distorted, damaged or disclosed to unauthorized third parties. To this end, this data is recorded in secure areas not accessible to the public. Additionally, the hosting infrastructure is itself protected against intrusions via multiple security layers.
Disclosure of personal data
The personal data collected on the Website is intended exclusively for Neolane’s use and will not be transmitted to third parties under any circumstances, with the exception that Neolane may pass this information on to some of its partners where appropriate, in the context of jointly developed services.
Furthermore, according to the limits permitted by law and without prejudice to the other stipulations of this Policy, Neolane reserves the right to disclose such data:
- when Neolane has legitimate reasons for thinking that this disclosure is necessary to (i) identify, (ii) get in contact with, or (iii) bring legal action against a person engaging in an illegal activity or violating the rights or property of Neolane, Users or third parties;
- at the request of legal or administrative authorities and under the conditions stipulated by law;
- in the case of a sale, merger or any other transfer of assets.
By using the Website, Visitors expressly agree to Neolane passing on their information to the third parties mentioned above.
Neolane complies with all relevant regulations and takes all commercially reasonable steps to keep this personal information confidential and secure.
Messages from Neolane
Neolane will need to communicate with Visitors, once they have registered and sent their personal information, in order to answer their questions or provide the requested service (information/documentation requests, event registration). Messages may be sent by e-mail, mail or telephone. Furthermore, Users and Visitors are likely to receive marketing messages several times a year. In both cases, Neolane offers the option to refuse these types of messages. Please refer to the “Choices / Opting out” section of the Policy.
Choices/Opting-out
Visitors registered on the Website or Users of the Program who no longer wish to receive messages from Neolane or be included in the Neolane database may unsubscribe by following the instructions at the bottom of each message sent by Neolane, or by sending a letter to Neolane at its head office, addressed to the Neolane Marketing department.
Neolane’s address can be obtained via the following link: http://www.neolane.com/usa/contact/index
Access to data and correction
Visitors can at any time correct, update or remove personal information provided when registering, by sending a letter to Neolane’s head office, addressed to the Neolane Marketing department.
Neolane’s address can be obtained via the following link: http://www.neolane.com/usa/contact/index
Neolane will reply to each such request within a reasonable time.
Change of Policy
Neolane reserves the right to make changes to these rules. Certain modifications will be made in accordance with changes made to current laws and regulations. As new functions and new services are added, Neolane will continue to handle personal information in accordance with these rules.
We recommend you check this Policy regularly to remain informed of our rules and procedures concerning the handling of personal data.
Dispute resolution
For any claim relating to the handling of your personal information, please initially contact Neolane by sending a letter to its head office, addressed to the Neolane Marketing department.
Neolane’s address can be obtained via the following link: http://www.neolane.com/usa/contact/index
If Neolane has failed to respond to your claim, contact the national authority responsible for the protection of personal data directly.
In accordance with its commitment to respect the principles of Safe Harbor, Neolane has chosen the European “Data Protection” Panel as the independent appeal mechanism for any dispute related to the implementation of Safe Harbor. Thus, if Neolane has not been able to respond to your claim, contact the European “Data Protection” Panel: http://circa.europa.eu/Public/irc/secureida/safeharbor/library?l=/public_folder/complaint_form.
Questions
If you have any questions concerning this Policy, please contact Neolane by sending a letter to its head office, addressed to the Neolane Legal department.
Neolane’s address can be obtained via the following link: http://www.neolane.com/usa/contact/index
Copyright
The NEOLANE brand is a protected trademark. NEOLANE’s products and services are protected by intellectual property rights.
II. Protection Contact data
Data collected by the Users of the Neolane Program
The licence and maintenance agreement for the Neolane Program contains a contractual clause reminding Users of their legal obligations concerning the protection of personal data.
Neolane advises its customers collecting, using, handling, storing or disclosing personal data from the European Union or outside the European Union, to respect the Safe Harbor principles.
If Neolane discovers that one of its customers is violating the legislation concerning the protection of personal data, Neolane will inform the relevant authorities of such actions.
According to European directive 95/46/EC, Neolane is considered to be a “sub-contractor”. Consequently, it is not responsible for handling personal data. The User is “responsible for handling” because it determines the purposes and means of handling personal data. Therefore, if you have any questions relating to the rules and practices concerning the use of your personal data by the Users of the Neolane Program, we ask you to contact them.
Data hosted on Neolane servers
The Neolane Program is available in hosted mode (or ASP - Application Service Provider - mode). When Users choose this mode of use, the information concerning their customers and prospects will be stored on servers belonging to Neolane. As a purely technical service provider, Neolane may occasionally need to access this data on the express instruction of the Users. The latter remain responsible for handling. Therefore, please consult their specific policy.
However, Neolane undertakes to do everything in its power to ensure the integrity and confidentiality of data. Please refer to the “Integrity and confidentiality of data” section of this Policy.
Anti-spam policy
Neolane has set up an anti-spam policy on its website, available at the following address: www.neolane.com/usa/acceptable-use-policy.htm. The purpose of this Policy is to raise the awareness of Neolane Users to this issue and ensure they adopt sound practices in the use of the Program, particularly with regards to communication with third parties.
Neolane reserves the right to suspend or terminate the contract of Customers who fail to respect this Policy.
Recommended practices
Neolane is a member of the Messaging Anti Abuse Working Group (MAAWG), a forum for the messaging industry to combat spam, viruses and attacks resulting in a refusal of service and other on-line operations.
Neolane is also a member of the Email Sender & Provider Coalition (ESPC). This is a working group that consists of leading companies practising e-mail marketing with the aim of developing solutions to prevent the proliferation of spam and problems relating to the deliverability of e-mail messages.
Neolane recommends that Users of the Program using e-mails as means of communication join MAAWG and the ESPC. For more information, go to: www.maawg.org; www.espcoalition.org.
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