| Privacy
Policy Seven Corners,
Inc. and it's Agents consider privacy with the utmost of seriousness and is strongly
committed to protecting the privacy of visitors and users of our site and services.
Safe Harbor
Data Privacy Notice: We
adhere to the Safe Harbor Principles published by the U.S. Department of Commerce
(the "Safe Harbor Principles") with respect to personal information
(as defined below) it receives from the European Union. This
notice outlines our general policy and practices for implementing the Safe Harbor
Principles, including the type of information to which this notice applies, how
we use personal information, and the choices individuals have regarding our use
of, and their ability to correct, that personal information. If there is any conflict
between the policies in this notice and the Safe Harbor Principles, the Safe Harbor
Principles will govern. This
notice applies to all personal information we handle, including on-line (except
as noted below), off-line, and manually processed data. For purposes of this notice,
"personal information" means data that:
* is transferred from the European Union to the United States; * is recorded
in any form; and * is about, or pertains to, a specific individual who is
identified in, or is identifiable from, the data. "Sensitive
information" is a subcategory of personal information. Sensitive information
is defined as personal information specifying medical or health conditions, racial
or ethnic origin, political opinions, religious or philosophical beliefs, trade
union membership, or the sex life of the individual. Sensitive information also
includes personal information received from a third party where the third party
treats and identifies it as sensitive. Safe
Harbor Principles Regarding Personal Information Notice
and Choice: We
notify individuals about the personal information we collect from them, how we
use it, and how to contact us with privacy concerns. We obtain personal information
only as permitted by the Safe Harbor Principles or with the consent of the individual
affected. Consent for personal information to be collected, used, and/or disclosed
in certain ways may be required in order for an individual to obtain or use our
services. To the extent permitted under the Safe Harbor, we reserve the right
to process personal information in the course of providing professional services
to our clients without the knowledge of individuals involved. Disclosures
and Transfers: We
do not disclose 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 permitted by law or mandatory professional standards; * The disclosure
is reasonably related to the sale or other disposition of all or part of our business
or assets; * The personal information to be disclosed is publicly available;
* The party to whom the disclosure is made controls, is controlled by, or is under
common control with Seven Corners, Inc.; * The disclosure is reasonably necessary
for the establishment or maintenance of legal claims; or * The disclosure
is to persons or entities for whom we are providing services, provided the disclosure
is consistent with the purpose for which the personal information was obtained. We
will comply with the Safe Harbor Principles with respect to disclosures of sensitive
information, including, when applicable, obtaining the explicit consent of the
individual prior to disclosing sensitive information to a third party or using
sensitive information for purposes other than those for which it was originally
collected or subsequently authorized by the individual. Transfers of information
permitted under this notice, either to third parties or within Seven Corners,
Inc., include the transfer of data from one jurisdiction to another, such as transfers
to and from the United States of America. Data
Security, Integrity, and Access: We
employ physical, electronic, and managerial measures, including education and
training of our personnel, designed to provide the personal information in our
possession with reasonable protection from accidental loss or destruction, improper
use, alteration, or disclosure. Personal information collected or displayed through
a Web site is protected in transit by industry standard encryption processes.
However, we cannot guarantee the security of personal information accessible on
or transmitted via the Internet. We
process personal information in ways compatible with the purpose for which the
personal information was collected, or as otherwise 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. If
an individual becomes aware that personal information we maintain about that individual
is inaccurate, or if an individual would like to update or review his or her personal
information, the individual may contact us using the contact information below.
As a security precaution, we may request that the individual provide identifying
information such as name, address, birth date, and/or social security number.
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. Accountability
and Enforcement: We
established a program to monitor our adherence to the Safe Harbor Principles and
to address questions and concerns regarding our adherence. With
respect to any dispute relating to this notice that cannot be resolved through
our internal processes, we will cooperate with competent European Union data protection
authorities and comply with the advice of such authorities. In the event that
we or such authorities determine that we did not comply with this notice, we will
take appropriate steps to address any adverse effects and to promote future compliance. Amendment: We
may amend this notice from time to time by posting a revised notice on this Web
site, or a similar Web site that replaces this Web site. If we amend the notice,
the new notice will apply to personal information previously collected only insofar
as the rights of the individual affected are not reduced. So long as we profess
to adhere to the Safe Harbor Principles, we will not amend this notice in a manner
inconsistent with the Safe Harbor Principles. Information
Subject to Other Policies: We
are committed to following the Safe Harbor Principles for all personal information,
as that term is defined herein. Other information we receive may be subject to
policies that may differ in some respects from the policies set forth in this
notice. Certain of our Web sites have their own privacy policies that apply specifically
to those Web sites. Those policies may be accessed through the Web sites in question.
Information relating to present or former Seven Corners, Inc. personnel is subject
to our policies concerning personnel data privacy, which are available to present
and former Seven Corners, Inc. personnel upon request. Information obtained from
or relating to clients or former clients is further subject to the terms of any
privacy commitment made to the client, any agreements with the client, and/or
any applicable laws and professional standards. |