Safe Harbor

ESPO Systems Safe Harbor Policy
Introduction
ESPO Systems (the “Company”), a division of ESPO Corporation, is a provider of IT services. Protecting consumer privacy is important to the Company.
The company 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. The company has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement (the “Principles”). To learn more about the Safe Harbor program, and to view the company’s certification, please visit: http://www.export.gov/safeharbor/.
If there is any conflict between the policies in this privacy policy and the Principles, the Principles 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.
Definitions
“Personal Information” or “Information” means information that (1) is transferred from the EU and Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.
“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
Principles Notice
Company 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 Company discloses or may disclose that Information. Company 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 the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which it was originally collected.
Choice
The Company 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, the Company 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. Company shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.
Onward Transfers
Prior to disclosing Personal Information to a third party, Company shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Company shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles 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.
Data Security
Company shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Company 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. Company cannot guarantee the security of Information on or transmitted via the Internet.
Data Integrity
Company shall only process Personal Information 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, Company shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.
Access
Company shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, 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.
Enforcement
Company uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the 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 Personal Information in accordance with the Principles.
If a complaint or dispute cannot be resolved through our internal process, we agree to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the Safe Harbor Privacy Principles, as well as to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland. The panel may be contacted at ec-dppanel-secr@ec.europa.eu and the EU DPAs may be contacted directly via the information provided at http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm The contact information for the Swiss FDPIC can be found at: http://www.edoeb.admin.ch/kontakt/index.html?lang=en
Amendments
This privacy policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on this website.
Information Subject to Other Policies
The Company is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of the Company that may differ in some respects from the general policies set forth in this privacy policy.
Contact Information
Questions, comments or complaints regarding the Company’s Safe Harbor Policy or data collection and processing practices can be mailed or emailed to:
ESPO Systems
845 Midway Dr.
Willowbrook, IL 60527
Attn: Legal Department
orders@esposystems.com

Effective date: April 29, 2015