Safe Harbor Privacy Policy
SAFE HARBOR PRIVACY POLICY
The privacy and security of your information is important to Elephant Outlook, LLC (“Elephant Outlook”). Elephant Outlook has certified that it abides by the Safe Harbor privacy principles as set forth by the U.S. Department of Commerce regarding the collection, storage, use, transfer and other processing of Personal Information transferred from the European Economic Area (“EEA”) or Switzerland to the United States.
For purposes of this policy, “Customer” means any business customer that obtains products or services from Elephant Outlook.
“User” means any individual located in the EEA or Switzerland who provides personal information to us or uses Elephant Outlook products or services or.
“Personal Information” means any information that (i) is transferred by a Customer or User from the EEA or Switzerland to Elephant Outlook in the U.S., and (ii) relates to a specific individual.
Elephant Outlook’s Safe Harbor certification can be found at http://safeharbor.export.gov. For more information about the Safe Harbor principles, please visit www.export.gov/safeharbor.
How We Obtain Personal Information
Elephant Outlook may obtain Personal Information from various sources. Customers and Users may choose to submit Personal Information directly to us. They may do so, for example, on our websites or through web interfaces, or when contacting our customer service call center. In addition, Customers and Users may upload data, including Personal Information, to our servers in connection with obtaining or using our products and services. In all cases, as described below, Elephant Outlook’s practices regarding the collection, storage, use, transfer and other processing of Personal Information comply with the Safe Harbor principles of notice, choice, onward transfer, access, security, data integrity and enforcement.
Notice
Elephant Outlook provides information in its website privacy policies regarding the company’s Personal Information practices. We have also informed our Customers that they may be responsible for providing appropriate notice to Users whose Personal Information they provide to Elephant Outlook in the U.S.
Choice
In circumstances in which Elephant Outlook collects Personal Information directly from Users, we offer Users the opportunity to direct Elephant Outlook not to (i) disclose their Personal Information to certain third parties, or (ii) use their Personal Information for a purpose that is incompatible with the purpose for which the information was originally collected or subsequently authorized by the User. To exercise these choices, Users may contact us as specified in the “How to Contact Us” section of this policy.
When we receive Personal Information from Customers, or when Customers or Users upload data, including personal information, to our servers in connection with using Elephant Outlook products or services, we do not share the information with third parties (except as described in this policy), or use the information for purposes (i) that are incompatible with the purposes for which the information was provided to Elephant Outlook or (ii) that were subsequently authorized by Users to whom the information pertains.
Elephant Outlook may disclose Personal Information without offering individuals an opportunity to opt out (i) to our services providers, (ii) if required to do so by law or legal process, (iii) to law enforcement authorities, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual fraudulent or illegal activity. Elephant Outlook also reserves the right to transfer Personal Information in the event the company sells or transfers all or a portion of its business or assets. Should such a sale or transfer occur, Elephant Outlook will use reasonable efforts to direct the transferee to use the Personal Information in a manner that is consistent with applicable Elephant Outlook privacy policies and this Safe Harbor Privacy Policy. Following such a sale or transfer, Users may contact the entity to which Elephant Outlook transferred their Personal Information with any inquiries concerning the processing of that information.
Onward Transfer of Personal Data
Elephant Outlook requires service providers, business partners, representatives and affiliates to which the company discloses Personal Information and who are not subject to laws based on the European Union Data Protection Directive 95/46, Swiss Federal Data Protection Law or other adequacy finding to either (i) subscribe to the Safe Harbor principles or (ii) contractually agree to provide at least the same level of protection for Personal Information as is required by the relevant Safe Harbor principles.
Access
Where appropriate, Elephant Outlook provides Users with reasonable access to the Personal Information the company maintains about them. Elephant Outlook also provides a reasonable opportunity for Users to correct, amend or delete that information where it is inaccurate. We may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Safe Harbor principles. Users may request access to their Personal Information by contacting Elephant Outlook as indicated below.
In circumstances in which Elephant Outlook receives Personal Information from Customers, the company has informed the Customers that they are responsible for compliance with applicable data protection laws, including providing Users with access to their Personal Information and the right to correct, amend or delete the information where it is inaccurate. In these circumstances, Users should direct their questions to the appropriate Customer who provided their information to Elephant Outlook.
Security
Elephant Outlook takes reasonable precautions to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Data Integrity
Elephant Outlook takes reasonable steps to ensure that the Personal Information the company processes is (i) relevant for the purposes for which it is to be used, (ii) reliable for its intended use, and (iii) accurate, complete and current. Elephant Outlook depends on its Customers and Users to update and correct Personal Information to the extent necessary for the purposes for which the information was collected or subsequently authorized by the Users.
Enforcement and Oversight
Elephant Outlook has established procedures for periodically verifying the company’s implementation of and compliance with the Safe Harbor principles. We conduct an annual self-assessment of the company’s Personal Information practices to verify that the attestations and assertions Elephant Outlook makes about its privacy practices are true and that the company’s privacy practices have been implemented as represented.
Users may file a complaint concerning Elephant Outlook’s processing of their Personal Information by contacting us as specified in the “How to Contact Us” section of this Safe Harbor Privacy Policy. If the complaint cannot be resolved through Elephant Outlook’s internal processes, we will cooperate with JAMS pursuant to the JAMS International Mediation Rules, which are accessible on the JAMS website at www.jamsadr.com/rules-international-rules. We will take steps to remedy any issues arising out of a failure to comply with the Safe Harbor principles.
JAMS mediation may be commenced as set forth in the JAMS International Mediation Rules. The mediator may propose any appropriate remedy, such as publicity for findings of non-compliance, payment of compensation for losses incurred as a result of non-compliance, or cessation of processing of the Personal Information of the individual who has brought the complaint. Elephant Outlook will assume the costs of the administrative fees if the mediator makes a written recommendation that finds the company in breach of its duties pursuant to the Safe Harbor. The mediator or the individual also may refer the matter to the U.S. Federal Trade Commission, which has Safe Harbor enforcement jurisdiction over Elephant Outlook.
How to Contact Us
If you have any questions or comments about this Safe Harbor Privacy Policy, or if you would like us to update the information we have about you or your preferences, please contact us at:
Elephant Outlook
Attention: Legal and Privacy
Post Office Box 111
Winter Haven, FL 33880
Policy Effective Date: May 23, 2011
