Force 5 Media, Inc. ("Force 5 Media", "we" or "us"), conducts its business in accordance to the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission and the Frequently Asked Questions (FAQs) issued by the Department of Commerce on July 21, 2000 (collectively "Principals"). This Safe Harbor Privacy Statement ("Statement') sets forth the privacy principles that Force 5 Media follows with respect to transfers of personal information from the European Union ("EU") to the United States. Force 5 Media is an agent on behalf of its customers and therefore processes data only in accordance with the instructions of its customers.
Notice. As an agent processing personal information under the direction of its customers, Force 5 Media has no direct relationship with the individuals whose personal data it processes. Force 5 Media works with its customers to help them provide notice of data processing to individuals including information concerning (1) the purposes for which personal information is collected and used; 2) a contact person to whom inquiries or complaints may be directed; 3) the types of third parties to whom personal information is disclosed; and 4) the choices and means that individuals are offered for limiting use and disclosure of personal information.
Choice. As an agent processing personal information under the direction of its customers, Force 5 Media has no directly relationship with the individuals whose personal data it processes. Force 5 Media may disclose personal information to third parties in the following instances:
Force 5 Media works with its customers to help them inform individuals about the possibility of such disclosures and provide individuals with the choice of opting-out of them. Force 5 Media only processes personal information as directed by its customers. As agent of its customers, Force 5 Media may process non-personally identifiable sensitive information. However, the information gathered is not aggregated with the user's personal information so the information is never connected to the individual.
Onward Transfer. Personal information may be transferred to third parties as set out in this Statement in the Notice and Choice provisions with knowledge and consent of Force 5 Media's customers. Force 5 Media has agreements with these third party vendors requiring that they provide at least the same level of privacy protection as do the Safe Harbor Principles. As set out in the U.S. Safe Harbor Principles, adherence to the Principles may be limited to : 1) the extent necessary to meet national security, public interest, or law enforcement requirements; 2) by statute, government regulation, or case law that creates conflicting obligations or explicit authorizations provided that in exercising any such authorization, an organization can demonstrate that its non-compliance with the Principles is limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization; or 3) if the effect of the Directive or Member State law is to allow exceptions or derogations, provides such exceptions or derogations are applied in comparable contexts.
Security. Although we cannot guarantee the impenetrability of our servers, we have established and implemented reasonable precautions to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. As an agent processing personal information under the direction of its customers, Force 5 Media has entered into a contract with its customers specifying the conditions under which personal information received from the EU are processed and kept secure. Force 5 Media has appropriate contractual language in place with third party data processors providing that they must apply the Safe harbor Principles to the processing of personal data received from Force 5 Media.
Data Integrity. Force 5 only processes personal data that is relevant to the services it provides, and only for the purposes compatible with those for which the data was collected. As an agent processing personal information under the direction of its customers, Force 5 Media works with its customers so that they can provide a way for individuals to correct their data.
Access. As an agent, Force 5 Media has no direct relationship with the individuals whose personal information it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his inquiry to Force 5 Media's customer (the data controller) which has transferred such data to Force 5 Media for processing. Force 5 Media's customer will then provide access to the individual as determined under the applicable local data protection law.
Enforcement. We welcome your questions, comments and concerns about privacy. Please contact us at firstname.lastname@example.org with any questions or comments you may have regarding the privacy of your information. Individuals who wish to file a complaint or who take issue with Force 5 Media's Statement should contact us at email@example.com. Force 5 Media will explain the process to be followed when filing a complaint. Filing a complaint in English will expedite the process. Force 5 Media will work with its customer to investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Statement. In order to comply with the European Union's Safe Harbor principles, Force 5 Media commits to the resolution of complaints about your privacy and our collection or use of your personal information. We have committed to resolve any complaints by European Union citizens relating to this policy, which cannot be resolved directly with our company, through the Council of Better Business Bureaus, Inc's Safe Harbor Privacy Dispute Resolution Procedure.
If you have any questions regarding this policy, please contact Force 5 Media at firstname.lastname@example.org.
If you do not receive acknowledgement of your complaint or your complaint is not satisfactorily addressed by Force 5 Media, you should then contact:
Council of Better Business Bureaus, Inc.
4200 Wilson Boulevard, Suite 800
Arlington, VA 22203
Force 5 Media is also subject to the jurisdiction of the U.S. Federal Trade Commission ("FTC"). Should an individual be unable to resolve a complaint through the Council of Better Business Bureau's complaint process, they may contact the FTC at the following address:
Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580
The practices described in this Statement are effective November 10, 2008. Force 5 Media reserves the right to modify this Statement at any time consistent with the requirements of the Principles. Modifications to this Statement will be posted on Force 5 Media's Website and will be effective when posted.