Cybercon Safe Harbor Policy

Introduction

Cybercon and its affiliated United States subsidiaries (hereinafter collectively referred to as the "Cybercon", "We,", "us" or "our") adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union ("EU") the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the "Principles") with respect to all such data. 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 Cybercon whether in electronic, paper or verbal format.

Definitions

"Personal Information" or "Information" means information that (1) is transferred from the EU 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

The principles in this Policy have been developed based on the Safe Harbor Principles.

Notice

Cybercon 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 we discloses or may disclose that Information. Cybercon 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 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.

Choice

Cybercon 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, Cybercon 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. Cybercon 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, Cybercon shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. We 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

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.

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.

Access

Cybercon 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

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. We encourage interested persons to raise any concerns contact us at:

  Cybercon
  210 North Tucker Blvd. Ste 700
  St. Louis, MO. 63101
  Phone: 314-621-9991

  For Cybercon current customers, you can also contact us through the ticket system via Cybercon SMC portal.

We will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles of US-EU and US-Swiss Dafe Harbor.

If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using a third party resolution provider, the BBB EU Safe Harbor, operated by Council of Better Business Bureaus. You may contact them by visiting the following URL


http://www.bbb.org/us/safe-harbor-complaints

 

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

Cybercon 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 Cybercon 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:

Cybercon
Attn: Legal Department

210 North Tucker Boulevard, Suite 700
Saint Louis, MO 63101

Email: legal@cybercon.com
Effective date: October 1st, 2011