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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 EU to
the United States. The EEA also has recognized the U.S. Safe Harbor as
providing adequate data protection (OJ L 45, 15.2.2001, p.47).
Consistent with its commitment to protect personal privacy, Pro-softnet
Corp. adheres to the Safe Harbor Principles.
This Safe Harbor Privacy Policy (the "Policy") applies to all personal
information received by Pro-softnet Corp. in the United States in any
format including electronic, paper or verbal.
For purposes of this Policy, the following definitions shall apply:
"Pro-softnet Corp." will refer to its IDrive service (http://www.idrive.com)
a wholly owned subsidiary of Pro-softnet Inc.). "Personal information"
means any information or set of information that identifies or could be
used by Pro-softnet Corp. or its agents to identify an individual.
Personal information does not include information that is encoded or
anonymized, or publicly available information that has not been
combined with non-public personal information. "Sensitive personal
information" means personal information that reveals race, ethnic
origin, political opinions, religious or philosophical beliefs, or
trade union membership, or that concerns health or sex life. In
addition, Pro-softnet Corp. will treat as sensitive personal
information any information received from a third party where that
third party treats and identifies the information as sensitive.
Pro-softnet Corp. has instituted measures and mechanisms to ensure
adherence to the European Union Safe Harbor Privacy Principles. Among
other requirements, adherence involves engaging an independent third
party to resolve privacy disputes. If you are a European consumer and
feel your privacy dispute or complaint has not been adequately
resolved, the Council of Better Business Bureaus
has been contracted by Pro-softnet Corp. to handle complaints that
allege a failure to comply with the Safe Harbor Privacy Principles.
Pro-softnet Corp. may disclose Personal Data, including the data you
back up with the Service, with or without notice (a) if required by a
subpoena or other judicial or administrative order, (b) where required
by law, or (c) at our sole discretion, where we deem it necessary to
protect the safety of any individual or the general public or to
prevent violation of our User Agreement or the rights of Pro-softnet
Corp. or any third party.
Although Pro-softnet Corp. currently operates as an independent
corporation incorporated in the USA, any subsidiaries, joint ventures,
or other companies under a common control (collectively, "affiliates"),
it may in the future, Pro-softnet Corp. may share some or all of your
Personal Data with these affiliates, in which case it will require our
affiliates to honor this Privacy Policy.
In the event of a change in ownership, or a direct merger or
acquisition with another entity, we reserve the right to transfer all
of Pro-softnet Corp. User information, including Personal Data, to a
separate entity. We will use commercially reasonable efforts to notify
you (by posting on our website or an email to the email address you
provide when you register) of any change in ownership, merger or
acquisition of Pro-softnet Corp. assets by a third party, and you may
choose to modify any of their registration information at that time.
You may, at any time, choose to correct or update the information you
have submitted to Pro-softnet Corp., by updating your account on our
website (http://www.idrive.com).
If you cancel your account, your Personal Data and other information
may be retained in our archive or backup records.
The privacy principles in this Policy are based on the Safe Harbor Principles.
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NOTICE:
Where Pro-softnet Corp. collects personal information directly from
individuals in the EEA, it will inform them about the purposes for
which it collects and uses personal information about them, the types
of non-agent third parties to which Pro-softnet Corp. discloses that
information, and the choices and means, if any, Pro-softnet Corp.
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 to Pro-softnet Corp., or as soon as practicable thereafter,
and in any event before Pro-softnet Corp. uses the information for a
purpose other than that for which it was originally collected.
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CHOICE:
Where Pro-softnet Corp. collects personal information directly from
individuals in the EEA, Pro-softnet Corp. 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. For sensitive personal
information, Pro-softnet Corp. will give individuals the opportunity to
affirmatively and explicitly (opt-in) consent to the disclosure of the
information to a non-agent third party or the use of the information
for a purpose other than the purpose for which it was originally
collected or subsequently authorized by the individual. Pro-softnet
Corp. will provide individuals with reasonable mechanisms to exercise
their choices.
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ONWARD TRANSFERS TO AGENTS:
Pro-softnet Corp. will obtain assurances from its agents that they will
safeguard personal information consistent 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, being
subject to EU Directive 95/46/EC (the EU Data Protection Directive),
Safe Harbor certification by the agent, or being subject to another
European Commission adequacy finding. Where Pro-softnet Corp. has
knowledge that an agent is using or disclosing personal information in
a manner contrary to this Policy, Pro-softnet Corp. will take
reasonable steps to prevent or stop the use or disclosure.
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SECURITY:
Pro-softnet Corp. will take reasonable precautions to protect personal
information in its possession from loss, misuse and unauthorized
access, disclosure, alteration and destruction.
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DATA INTEGRITY:
Pro-softnet Corp. will use personal information only in ways that are
compatible with the purposes for which it was collected or subsequently
authorized by the individual. Pro-softnet Corp. will take reasonable
steps to ensure that personal information is relevant to its intended
use, accurate, complete, and current.
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ACCESS:
Upon request, Pro-softnet Corp. will grant individuals reasonable
access to personal information that it holds about them. In addition,
Pro-softnet Corp. will take reasonable steps to permit individuals to
correct, amend, or delete information that is demonstrated to be
inaccurate or incomplete.
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ENFORCEMENT:
Pro-softnet Corp. will conduct compliance audits of its relevant
privacy practices to verify adherence to this Policy. Any employee that
Pro-softnet Corp. determines is in violation of this policy will be
subject to disciplinary action up to and including termination of
employment.
Any questions or concerns regarding the use or disclosure of personal
information should be directed to Pro-softnet Corp. at the address
given below. Pro-softnet Corp. 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.
If you have a complaint about any aspect of privacy infringement on
Pro-softnet Corp., we request that the complainant first try to resolve
the issue by interacting with us at safeharbor@idrive.com
with subject line clearly indicating the issue and a detailed
description in the text of the email/mail to our official
correspondence address indicated below under “Contact Information”.
For
complaints that cannot be resolved between Pro-softnet Corp. and the
complainant, Pro-softnet Corp. has agreed to participate in the dispute
resolution procedures established by BBB OnLine to resolve disputes
pursuant to the Safe Harbor Principles.
If you have any questions or comments, contact us at safeharbor@idrive.com. Although we strongly prefer email communication, you may also send regular postal mail to:
IDrive DIVISION,
Pro-softnet Corporation,
21300 Victory Blvd Suite 690
Woodland Hills CA 91367
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 material amendments or changes to this Policy.
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