Cybercon Privacy Shield Policy

1) Introduction
Cybercon and its affiliated United States subsidiaries (hereinafter collectively referred to as “Cybercon”, “vServerCenter”, “we,” “us” or “our”) adhere to the Privacy Shield Framework concerning the transfer of personal data from the European Union (“EU”) to the United States of America (“US”). Cybercon complies with the Eu-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Cybercon has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view our certification page, please visit https://www.privacyshield.gov

2) Definitions
“Personal Information” or “Information” means information that (a) is transferred from the EU to the United States; (b) is recorded in any form; (c) is about, or pertains to a specific individual; and (d) 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.

3) Information We Collect
At the point of sale, we request customer contact information (ie: company name, contact name, address, phone and email) as well as billing information (ie: credit card number, expiration date). We utilize a credit card processor to facilitate product payment.

4) Principles
The principles in this Policy have been developed based on the Privacy Shield Principles.

5) Notice
Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to us, or as soon as practicable thereafter, and in any event before Cybercon uses or discloses the Information for a purpose other than for which it was originally collected.

6) Choice
Cybercon has never shared customer information with any non-agent third party for any reason. If this practice should change in the future, we will update this privacy policy and provide individuals with opt-out choice.

7) Onward Transfers
Cybercon has never shared customer information with any non-agent third party for any reason. If this practice should change in the future, we will update this privacy policy and provide individuals with opt-out choice. Cybercon remains responsible and liable under the Privacy Shield Principles if third party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Cybercon proves that it is not responsible for the event giving rise to the damage. Furthermore, we may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

8) Data Security
Cybercon shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We 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. We cannot guarantee the security of Information on or transmitted via the Internet.

9) Data Integrity
Cybercon 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, We shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

10) Right to Access, Change or Delete Personal Data
Cybercon acknowledges the individual’s right to access their personal data. Cybercon shall allow an individual to 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.
Customers may edit their Personal Information by contacting us by phone or email. In making modifications to their Personal Information, customers must provide only truthful, complete, and accurate information. To request deletion Personal Information, Customers should submit a written request to the Cybercon office at the mailing address listed under Contact Information. Cyberson will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

11) Enforcement
Cybercon 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. In compliance with the EU-US Privacy Shield Principles, Cybercon commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Cybercon at the address found at the end of this policy
Cybercon has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. Cybercon is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

12) Amendments
This privacy policy may be amended from time to time consistent with the requirements of the Privacy Shield. We will post any revised policy on this website.


13) Dispute Resolution
In compliance with the Privacy Shield Principles, Cybercon commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Private Shield policy should first contact Cybercon at: [email protected]

If a Customer's question or concern cannot be satisfied through this process Avangate has further committed to refer unresolved privacy complaints under US-EU Privacy Shield to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus.

If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by Cybercon, EU individuals may bring a complaint before the BBB EU Online Privacy Shield. Information about how to file a complaint before the BBB EU Privacy Shield program can be found at: www.bbb.org/EU-privacy-shield/for-eu-consumers/. Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

14) Contact Information

Questions, comments or complaints regarding the Company’s Privacy Shield or data collection and processing practices can be mailed or emailed to:

  Cybercon
  Attn: Legal Department
  210 North Tucker Boulevard, Suite 700
  Saint Louis, Missouri 63101

  Email: [email protected]

Effective date: December 1, 2016