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You can visit websites without identifying yourself or revealing any personal information. Once you choose to provide us personally identifiable information (name, address, e-mail address, phone number, etc.) you can be assured that it will only be used to support your relationship with AMOT. Once you choose to use the login data that gives you access to closed user group sections on the AMOT websites, AMOT has the right to track your visits to the AMOT websites.
SAFE HARBOR PRIVACY POLICY
This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that AMOT. (The “Company”) follows with respect to transfers of personal information obtained from the European Economic Area (EEA) to the United States.
SAFE HARBOR
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States. The European Union also has recognized the U.S. Safe Harbor Program administered by the United States Department of Commerce as providing adequate data protection. Consistent with its commitment to protect personal privacy, the Company adheres to the Safe Harbor Principles with respect to personal information transferred from the Bertelsmann Reporting System to the Company in the United States. For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce's Website at http://www.export.gov/safeharbor/.
SCOPE
This Policy applies to all personal information received by the Company in the United States from the European Economic Area, in any format including electronic, paper or verbal.
PRIVACY PRINCIPLES
The privacy principles in this Policy are based on the Safe Harbor Principles.
NOTICE: Where the Company collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses such personal information, the types of non-agent third parties to which the Company discloses that information, and the choices and means, if any, the Company offers individuals 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 that will be available to the Company, or as soon as practicable thereafter, and in any event before the Company uses the information for a purpose other than that for which it was originally collected.
CHOICE: The Company will offer individuals the opportunity to choose (opt-out) whether their Personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
The Company will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY: The Company will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. The Company will take reasonable steps to ensure that personal information is used for its intended purpose, and is accurate, complete and current.
ONWARD TRANSFERS: The Company will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding. Where it has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, the Company will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, the Company will grant individuals reasonable access to personal information that it holds about them. In addition, the Company will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: The Company will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT: The Company will periodically conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. The Company will remedy issues arising out of any failure to comply with this Policy, and any employee that the Company determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
The Company acknowledges that its failure to provide an annual self-certification to the Department of Commerce will remove it from the Department’s list of participants and thereafter the transfers of personal information will not be allowed unless the Company otherwise complies with the EU Data Protection Directive.
DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Company Privacy Office at the address given below. The Company 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. For complaints that cannot be resolved between the Company and any EU-based complainant, the Company has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.
CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to the Company Privacy Office by mail or e-mail as follows:
AMOT
Human Resources Department
8824 Fallbrook Drive
Houston, Texas 77064
CHANGES TO THIS SAFE HARBOR PRIVACY POLICY
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning such amendments.
EFFECTIVE DATE: May/27/2009
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