This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that RealSecurityPro.com follows with respect to transfers of personal information anywhere in the world, including transfers from the European Economic Area (EEA) (which includes the 15 member states of the European Union (EU) as well as Iceland, Liechtenstein and Norway) to the United States.
Personal information that is transferred to RealSecurityPro.com in the United States from the EU falls under one of the following three situations:
Processor on Behalf - RealSecurityPro.com provides corporate communications software designed to help companies automate workflow and manage media information more effectively. RealSecurityPro.com does not own or control any of the information it processes on behalf of RealSecurityPro.com’s customer. All such information is owned and controlled by RealSecurityPro.com’s customer. In this capacity, RealSecurityPro.com receives information transferred from the EU to the United States merely as a processor on behalf.
Data Controller - RealSecurityPro.com also provides business information products designed to help companies market themselves more successfully. In this function, RealSecurityPro.com acts as a data controller of the personal information contained in these information products.
Personal Data Collection - RealSecurityPro.com may, in certain instances, itself collect data to improve its processes and products. This data collection is designed primarily to update RealSecurityPro.com database of media contacts and to monitor the efficacy of various types of information distributed using RealSecurityPro.com software or other products.
RealSecurityPro.com has appointed a privacy officer who is responsible for the internal supervision of RealSecurityPro.com’s privacy policies and data security. RealSecurityPro.com is committed to educating its customers and associates (employees) in the United States and in the EU about the issues, guidelines and laws surrounding compliance with EU Safe Harbor.
RealSecurityPro.com’s privacy officer and its legal team are available to any associate (employee) who may have questions concerning RealSecurityPro.com’s EU Safe Harbor privacy policies or data security practices.
Since the requirements for compliance with EU Safe Harbor vary depending on whether RealSecurityPro.com is acting as a processor on behalf of RealSecurityPro.com’s customer or a data controller, RealSecurityPro.com’s policies and manner of compliance are described separately below.
RealSecurityPro.com as a Processor on Behalf - When RealSecurityPro.com acts as a processor on behalf of its customer, the policies outlined below apply to all data processing operations concerning personal information that has been transferred from the EU to the United States.
Processing Contracts - Before starting any processing on behalf of RealSecurityPro.com’s customer, RealSecurityPro.com will enter into a processing contract with the EU data controller responsible for the personal information pursuant to the applicable EU Member State Data Protection law.
- The processing contract ensures that the EU data controller will be in compliance with the Member State Data Protection law. Any data processed by RealSecurityPro.com will not be further disclosed to third parties except where permitted or required by the processing contract, EU Safe Harbor or the applicable Member State Data Protection law. Any information which RealSecurityPro.com’s customer (acting as the EU controller) identifies as sensitive will be treated accordingly.
The processing contract will also specify that the processing will be carried out with appropriate data security measures. RealSecurityPro.com has in place measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction.
As a processor on behalf of RealSecurityPro.com’s customer (who is the EU controller), RealSecurityPro.com is not required to apply other EU Safe Harbor Principles to the personal information received for processing from a customer.
RealSecurityPro.com as a Data Controller or Data Collector - When RealSecurityPro.com acts as a data controller or data collector of personal information, the policies outlined below apply to all personal information that has been transferred from the EU to the United States.
RealSecurityPro.com develops and maintains databases containing personal information on European media contacts from a number of EU Member States. In instances where RealSecurityPro.com is a data controller, the information for these databases is developed from public records and from information acquired through information providers. In instances where RealSecurityPro.com is a data collector, the information for these databases is developed from email, telephone, or other responses by media contacts. None of these databases contain any information defined as sensitive by any national law of an EU Member State (e.g., the databases do not include information about race, religion, sexual orientation, and so forth).
RealSecurityPro.com’s databases contain information which is provided to qualified businesses for marketing and media relations purposes.
RealSecurityPro.com may also use Web beacons or other unique identifiers to allow it to determine which messages or elements of a media campaign generate responses. This allows RealSecurityPro.com software to gauge the effectiveness of certain communications. RealSecurityPro.com will, as a service to its clients, provide data regarding the campaign effectiveness; such information is designed to make more efficient the process of transmitting and receiving media campaign information.
As either a data controller or data collector, RealSecurityPro.com is required to comply with all principles of the EU Safe Harbor.
Notice - Prior to the transfer of any non-public personal information from the EU to the United States, RealSecurityPro.com requires contractual confirmation from the EU controller from whom RealSecurityPro.com acquired the information that the data subjects from whom the information was derived have been provided with proper notice pursuant to the applicable EU member state data protection law.
As indicated above, RealSecurityPro.com may collect information to maintain and update its database, improve its products, and provide information to its clients.
- Choice - Prior to the transfer of any non-public personal information from the EU to the United States, RealSecurityPro.com requires contractual confirmation from the EU controller from whom RealSecurityPro.com acquired the information that the data subjects from whom the information was derived have been provided with the choice to determine how their information may be used pursuant to the applicable EU member state data protection law.
- In addition, RealSecurityPro.com will, upon request, remove an individual’s name and related information from its information products.
- In order to request that RealSecurityPro.com not use an individual’s non-public personal information, such individual should contact RealSecurityPro.com’s consumer advocate at the address provided below or by sending an email to us at safeharbor@RealSecurityPro.com
- Written communication should be addressed as follows:
Consumer Advocate
EU Safe Harbor Opt-Out
RealSecurityPro.com
Exogeny Network Media Partners
6211 Airline Drive
Airline Park
Metairie, LA 70003-4332
Prior to making any alterations in its information, RealSecurityPro.com will require that individuals confirm their identity.
Data Integrity - RealSecurityPro.com takes reasonable steps to assure the information which is transferred from the EU to the United States is reliable, accurate and complete. The steps RealSecurityPro.com takes to assure data integrity are made in light of the purposes for which the personal information is used.
Onward Transfer - RealSecurityPro.com complies with the notice and choice principles as described above for all data which is disclosed or transferred to a third party.
RealSecurityPro.com may from time to time use agents to perform processing tasks on behalf and under the instruction of RealSecurityPro.com. RealSecurityPro.com requires that its agents either:
Subscribe to the EU Safe Harbor Principles, the EU Data Protection Directive or another adequacy finding; or
Enter into a written agreement with RealSecurityPro.com requiring them to provide the same level of protection as RealSecurityPro.com.
Security - RealSecurityPro.com will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. RealSecurityPro.com limits access to personal information and data to those persons in RealSecurityPro.com’s organization, or agents of RealSecurityPro.com, that have a specific business purpose for maintaining and processing such information and data. Individuals who have been granted access to personal information are aware of their responsibilities to protect the security, confidentiality and integrity of that information.
Any security compromises or potential security compromises and any inquiries concerning security should be reported to the RealSecurityPro.com consumer advocate. Contact information is provided below.
Access - An individual may make a request to RealSecurityPro.com for access to the information RealSecurityPro.com maintains in its information products. The individual has the right to receive confirmation from RealSecurityPro.com as to whether or not data relating to him/her is found in RealSecurityPro.com’s information products and to correct, amend, or delete that information when it is inaccurate. This right only applies to personal information relating to the individual making the request and is subject to other limitations as defined by law.
Individuals who wish to make an access request should direct such a request to RealSecurityPro.com’s Consumer Advocate in RealSecurityPro.com’s consumer affairs department at the address provided below or by sending an email to us at safeharbor@RealSecurityPro.com.