Connectria - Safe Harbor Privacy Policy for Certain European Users

We self-certify compliance with

Note: The policies and practices described herein apply only to EU and Swiss Personal Information subject to the Safe Harbor Frameworks.

This privacy policy explains how Connectria, LLC. (together with its subsidiaries and affiliates, "Connectria"), collects, uses, maintains, and discloses information collected from our clients, visitors to our website, individuals who contact us, and visitors to our clients websites (collectively, "Users").

Please note that users herein are classified in two mutually-exclusive categories and that the type of data collected varies depending upon the user's category:

Category One: With respect to users who request further information about our services, we collect only such information as is necessary to determine your level of service needs plus contact information to enable us to answer your questions as a prospective customer.

Category Two: Users who already are customers of Company and are using this domain as a portal to see the information on their server. The information collected from these users is broader in nature because they have consented to be our customers and the need to provide the highest level of customer service to these customers requires a more varied and sometimes more intrusive degree of access.

Important Note: Category One and Category Two users that are not covered by the so-called EU Directive on Data Protection and the US-EU Safe Harbor program or the US-Swiss Safe Harbor program should note that the instant Privacy Policy does not apply and instead you should review the policy at http://www.connectria.com/legal/privacy_policy.php.

By reading this Privacy Policy carefully, you may understand which personally identifying information ("PII", "Personal Information") of yours is collected, how and when we might use your information, who has access to this information, and how you can correct any inaccuracies in the information. It also allows you to "opt out" as further explained below.

Located in the U.S., Connectria endeavors to provide a safe, reliable, and improved service experience to clients and prospective clients, wherever they may be throughout the world. With respect to the possession, maintenance, management or transfer of personal data from the European Union (“EU”) or Switzerland to the United States (“EU and Swiss Transfer and Maintenance”), Connectria is committed to being in full compliance with global privacy and data security mandates, including the Safe Harbor Frameworks developed by the U.S. Department of Commerce in consultation with the European Commission (EC) and the Federal Data Protection and Information Commissioner of Swtizerland.

In order to offer the optimum service experience, it sometimes happens that we collect information from users who visit our website or come into possession of such information as a third party. We do not offer for sale, share, or lease any information possessed by us.

This Privacy Policy applies to prospective, current, and former Users.

The terms of this Privacy Policy are in addition to the terms of our Master Services Agreement for clients ("MSA"), Terms of Service ("TOS"), Terms & Conditions (T&C), Acceptable Use Policy ("AUP"), Copyright Infringement Protocol ("CIP"), Information Technology Services Agreement (“ITSA”), Order Forms, and any Statements of Work (SOW) entered into with a client, collectively known as Connectria Legal Policies, and any specialized contracts that may have been agreed upon.

We offer products and services that are provided by third parties ("Third Party Products"). These Third Party Products may collect and use information in ways that differ from those stated in this Privacy Policy. Please contact us if you would like a list of these third parties related to your service. Connectria does not take responsibility for how these Third Party Products utilize your information and we instruct you to visit the respective service provider's website for more information. Typically, these providers only require IP or hostname data. For further information about Third-Party Products, please see the Connectria TOS.

Safe Harbor Privacy Principles

Connectria and its affiliated United States subsidiaries adhere to the Safe Harbor Frameworks with respect to the EU and Swiss Transfer and Maintenance. Accordingly, we follow the respective Safe Harbor Privacy Principles (the “Principles”) and frequently asked questions ("FAQ") (collectively, "Safe Harbor Frameworks") published by the U.S. Department of Commerce with respect to all such data. If there is any conflict between the policies in this privacy policy and the Safe Harbor Frameworks, the latter shall govern. This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by the Company whether in electronic, paper or verbal format. In conflict situations, however, the Safe Harbor Frameworks only govern with respect to the Personal Information of Users that Connectria serves from the European Economic Area ("EEA") and Switzerland. Citizens of the EEA and Switzerland should know that the Safe Harbor Frameworks were devised by the United States Department of Commerce in conjunction with the European Commission and the Federal Data Protection and Information Commissioner of Switzerland with the specific goal of complying with the data protection laws of the European Union and Switzerland with respect to the protections that are given to personal identifying information transferred from the EU and Switzerland to the United States. However, Connectria does not represent that its Privacy Policy is compliant with EU and Swiss law in every respect, only that if substantially fulfills the U.S.-EU and U.S.-Swiss Safe Harbor requirements. The EEA has recognized the U.S.-EU Safe Harbor Framework as providing adequate data protection for these purposes.

For the convenience of EEA and Swiss patrons, the seven Safe Harbor Privacy Principles contained in this Privacy Policy are marked at the end of each respective section thus: {1}Notice, {2}Choice, {3}Onward Transfer, {4} Access, {5}Security, {6}Data Integrity, {7}Enforcement.

Connectria's Safe Harbor Certification can be found here: https://safeharbor.export.gov/companyinfo.aspx?id=24457

Notice

Connectria shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which Connectria discloses or may disclose that Information. Connectria shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Connectria, or as soon as practicable thereafter, and in any event before Connectria uses or discloses the Information for a purpose other than for which it was originally collected. {1}

Information We Collect
Connectria collects certain information from and about its users in three ways: (i) from our web server logs, (ii) with cookies, and (iii) directly from the user. {1}

Web Server Logs
When you visit our website, Connectria may collect information to administer the site and analyze its usage. Connectria may collect information such as:
- Your Internet protocol address;
- The type of browser or computer you use;
- The number of links you click within our website;
- The state or country from which you accessed our website;
- The date and time of your visit;
- The name of your Internet service provider;
- The Web page from which you linked to our website; and
- The pages you viewed on our website{1}

"Cookies"
Our website uses cookies and other passive information (as defined below). We use cookies to save your preferences and login information, and provide personalized functionality. You can reject cookies by changing your browser settings, or reconfiguring, but be aware that this will disable some of the functionality on the Connectria website. Users who choose not to accept cookies may be unable to access certain options, offers, and services that involve Connectria's interaction with that User. Tracking technologies may record information such as internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that the Connectria site is accessed. Connectria uses cookies and other tracking technologies to improve Connectria’s web site and Users’ hosting experience. Connectria may also analyze information that does not contain PII for trends and statistics. The web site's advertisers and other partners may also use cookies in connection with the services and websites to which the Website links. We do not control these cookies.

Passive information - Definitional subsection.
A "cookie" is a bit of information that a Web site sends to your Web browser that helps the site remember information about you and your preferences.

"Session" cookies are temporary bits of information that are used to improve navigation, block visitors from providing information where inappropriate (the site "remembers" previous entries of age or country of origin that were outside the specified parameters and blocks subsequent changes), and collect aggregate statistical information on the site. They are erased once you exit your Web browser or otherwise turn off your computer.

"Persistent" cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (such as passwords), helping to determine what areas of the Web site visitors find most valuable, and customizing the Web site based on your preferences on an ongoing basis. Persistent cookies placed by this site on your computer may hold personally identifiable information, but only if you have registered or have otherwise consented to the retention of personally identifiable information you have provided at the site. Otherwise, our site's server only knows that an unidentified visitor with your cookie has returned to the site.

You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. To learn more about cookies and how to specify your preferences, please search for "cookie" in the "Help" portion of your browser.

A site may use Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet service provider so you can access the Internet and is generally considered to be non-personally identifiable information, because in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user's computer). The IP address can be used to diagnose problems with a server, report aggregate information, determine the fastest route for your computer to use in connecting to a site, and administer and improve the site.

"Internet tags" (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the Web site server information such as the IP address and browser type related to the visitor's computer. Tags may be placed both on online advertisements that bring people to the site and on different pages of the site. Such tags indicate how many times a page is opened and which information is consulted.

"Navigational data" (log files, server logs, and clickstream data) are used for system management, to improve the content of the site, market research purposes, and to communicate information to visitors.{1}

Choice

Connectria will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, Connectria will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Connectria shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.{2}

Connectria shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which the Connectria discloses or may disclose that Information.{1}. Connectria shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information {2}. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Connectria, or as soon as practicable thereafter, and in any event before Connectria uses or discloses the Information for a purpose other than for which it was originally collected.{1}

Product Information

On some pages of our website users can register to purchase products or services, receive personalized content, and participate in surveys or forums. When you register, Connectria may ask you for some personal information. If you are purchasing products or services from Connectria, we will request financial information such as credit card or bank account information. Any financial information we collect is used only to bill you for the products and services you purchased. If you purchase by credit card, this information may be forwarded to your credit card provider. For other types of registrations or service inquiries, we will ask your name, address, e-mail address, or telephone number. We may then contact you with information about Connectria products and services.

Support and Access

As a service subscriber you may be asked to disclose personal information to Connectria so that we can provide technical support to you. We may collect personal information for account verifications in order to provide technical support and troubleshooting services over our helpdesk. If you choose to contact us via email, live chat, or helpdesk, we may retain a copy of the communication with your email address, account information, and our responses. Connectria makes reasonable effort to make sure all collected data is reliable, up to date, accurate and complete.

Additional Information

To preserve the integrity of our website and network, Connectria may use software programs to monitor network traffic or to identify unauthorized attempts to cause damage. These software programs may also collect information regarding your usage of our services, website, and network. As an internet service provider, Connectria provides access to servers for clients around the world to store and manage their data and applications. Connectria does not own this customer data and is not a "controller" as outlined in the EU Directive. Notwithstanding anything in this Privacy Policy to the contrary or apparently to the contrary, Connectria adheres to the Safe Harbor Privacy Principles only to the extent that Connectria is exposed to customer or user data as a result of the EU and Swiss Transfer and Maintenance.

How We Use Your Information

Customer Record and Inquiries
Connectria uses the information we collect to notify you about your account and to notify you about changes of the terms and conditions governing use of our websites, products and services. We may also use the information we collect to notify you about other products and services we think you will find valuable and about special offers. You may notify us of your desire not to receive notifications relating to new products and services and specials offers by .opting-out. as provided for below.

Our employees, contractors, or agents will at times require access to your personal information. Connectria permits access to this information only for business purposes such as administration and support for our products and services.

Information Released

Connectria may provide aggregate information about our clients, our website's traffic patterns, and related website usage information to our affiliates and reputable third parties, this information will never include personally identifying data. We take all available measures to select affiliates and service providers that are ethical and provide similar privacy protection to their clients and the community. We do not make any representations about the practices and policies about these companies.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials to enforce and comply with the law. We will disclose any information about Users upon valid request by government or law officials as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including without limitation subpoenas), to protect your property and rights, or the property and rights of a third party, to protect the safety of the public or any person, or stop activity we consider illegal or unethical.

Contacting You Directly

Connectria may contact you directly through the email address or other information provided upon account signup. Connectria will contact you to respond to your questions, to provide the services you request, to manage your account, and/or to inform you of any service announcements. If you require an account contact change, please submit a support ticket to our Support department via https://www.mh.connectria.com/rp

Opt-out

If you do not want to receive any non-account related materials from Connectria, you may opt out at any time. You may "opt out" by clicking the "Unsubscribe" link, or by sending a message with the subject "I do not wish to receive special communication from Connectria" to legal@connectria.com. Once this message is received, your account will be flagged and all reasonable measures will be taken to remove your account from future non-account pertinent mailings.

Third Party Service Providers

We may at times provide information about you to third parties to provide various services on our behalf such as processing credit card payments and hosting service add-ons. We will only share your information when necessary for the third party to provide the requested service. These service partners are prohibited from sharing or storing your personally identifiable information for any purposes unrelated to providing the said service.{3}

How We Protect Your Information

Connectria shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction (collectively, "Misappropriation"). Connectria has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Connectria cannot guarantee the security of information on or transmitted via the Internet. Connectria strongly recommends that your information be encrypted prior to providing it to us.

Contact with data by Connectria may happen in any of three ways: data in use (e.g., endpoint actions), data in motion (e.g., network actions), and data at rest (e.g., data storage). Connectria uses technical security measures to prevent Misappropriation of information or data under our control. Connectria uses security measures including and not limited to: firewalls, non public facing systems, complex passwords, anti-virus, and mitigation and detection software. When we ask clients or users to provide financial information (such as a credit card number) that data is protected using Secure Sockets Layer ("SSL") technology. However, please note that electronic communication (e.g.: email, online chat, or instant messaging) that you may send to us may not be secure unless we advise you in advance that security measures will be in place prior to your transmitting the information. For that reason, we ask that you do not send confidential information such as financial information, social security numbers, or passwords to us through unsecured electronic communication. {5}.

Access to Your Personal Information and Correction of Inaccuracies

If you wish to access and/or update the personal information we have collected from you, you may either login to our website or client systems and view and change your information or contact our help desk team via http://www.connectria.com. Connectria shall allow such corrections except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. If you would a list of client systems related to your account, this can also be obtained by contacting our Accounting team. {4}

Transfer to Third Parties

If you wish to transfer your account to a third party (e.g. new webmaster, new company owner), you must make this request to customer service. After your request is received we will provide a transfer of ownership form and we will complete an account standing and history audit. Once you have returned the account ownership request form your account and request will be verified by our Management team. Once the account ownership change is verified and processed, the new account owner will be protected by this Privacy Policy. {3}

Prior to disclosing Personal Information which involves an EU and Swiss Transfer and Maintenance to a third party, Connectria shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Connectria shall ensure that any third party for which such Personal Information may be disclosed subscribes to the Safe Harbor Frameworks or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.{2, 3}.

Transfer of Data Abroad

If you are visiting the Connectria website from a country other than the countries in which our networks are located, the various communications will necessarily result in the transfer of information across international boundaries. By visiting our website and communicating with us you consent to the processing and transfer of your data as set by this Privacy Policy.

Content Placed in Public

Technical support for some Connectria products or services is primarily provided by a user community which involves message boards or other online public activities. We strongly suggest users of these areas to use caution as any information disclosed in these areas is public information. Do not disclose information in these public forums that might be considered confidential such as financial information, passwords or email addresses. Users should be aware that when they voluntarily disclose personal identifiable information (PII) on message boards or other online communities, that information disclosed in the communication can be collected and used by third parties.{1}

Data Integrity

Connectria shall only process PII in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Connectria shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use. {6}

Children's Privacy

In conformity with the Children's Online Privacy Protection Act (COPPA), Connectria does not knowingly collect or solicit any personal information from children under the age of thirteen (13).

Modifications to the Privacy Policy

Connectria hereby reserves the right to amend, alter, modify, replace or suspend this Privacy Policy, from time to time, in its sole discretion. All changes to this Privacy Policy will be effective when posted on the Connectria website.

Ensuring Compliance with the Privacy Policy

Connectria uses a self-assessment approach to ensure compliance with this Privacy Policy and regularly verifies that the Privacy Policy is accurate, displayed, accessible, and with respect to EU and Swiss Transfer and Maintenance only, in conformity with, and within the guidelines of, the Safe Harbor Privacy Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of PII involving an EU and Swiss Transfer and Maintenance in accordance with the Principles. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider. {7}

Questions or Concerns

If you have any questions, comments, feedback regarding this Privacy Policy or the use and disclosure of personal information, please contact Connectria via email at legal@connectria.com and we will respond within a timely manner. If you are an EU or Swiss national, and we are unable to resolve your complaint or dispute internally, please know that we cooperate with the European Union Data Protection Authorities, as well as the Federal Data Protection and Information Commissioner of Switzerland. {7}

This Privacy Policy is effective as of August 27, 2010.

Please note that our specific application of the seven Safe Harbor Privacy Principles can be found in this Privacy Policy and are denoted with {1}-{7}.