Collection of Commercial Information
UpdatePower collects certain information involuntarily from visitors to its website, and those of its subsidiaries, including the IP address, time visited, pages viewed and related information. The Company also collects certain information voluntarily when someone sends a direct mail inquiry, an email or online registration, participates in seminars or webinars, or requests Company information at tradeshows. Examples of such information include individual names, telephone numbers, email addresses, Company name, person’s title, and other personally identifiable information. UpdatePower uses such information to monitor the performance, and improve the quality of, its website, respond to requests about the Company and its business, provide information about products and services, fulfill customer requests, marketing and other business purposes and to comply with various legal and/or regulatory requirements. The Company may share this information with business partners to respond to customer needs, or to engage in joint marketing activities. UpdatePower may also share this information with third-party agents who may be acting on its behalf; e.g., providing notice of an upcoming webinar or tradeshow that may be of interest to the target audience, or during solicitation for business purposes.
Collection of Personal and Sensitive Information
UpdatePower collects personal information only directly from the individuals affected. Personal information is information that identifies a particular individual, and does not include aggregated, compiled or publicly available data. Personal information that is related to commercial purposes is used as described in the preceding section. Sensitive information is personal information that reveals a particular person’s: (i) race; (ii) religion; (iii) ethnicity;(iv) sexual orientation; (v) political or philosophical beliefs; (vi) trade union membership; (vii) or information regarding a person’s medical status or condition. Sensitive information is collected solely for employment-related and other internal business matters, as well as to comply with legal and regulatory obligations.
Other Uses of Personal and Sensitive Information
In addition to the uses described above, UpdatePower will inform individuals of any other intended uses of their personal or sensitive information at the time such information is collected, or before such use is implemented, including disclosure to third parties that are not agents of UpdatePower. The individual will have the ability to advise the Company if he/she does not consent to such intended or additional use (i.e., "opt-in"). For other personal or commercial information, the individual has the ability to advise the Company at any time that he/she no longer wishes to allow such intended or additional use (i.e., "opt-out"), again, including disclosure to third parties that are not agents of UpdatePower.
UpdatePower will use reasonable methods to secure all personal and sensitive information by a variety of methods, including restricting access to such information only to those people who have a legitimate need to know in order to discharge their job responsibilities on behalf of UpdatePower, securing access to the facility where the information is stored, and the use of technology and physical controls to secure the information.
Use of Information by Third Parties That are Agents of UpdatePower
UpdatePower will require that all third parties that are acting on behalf of UpdatePower, and to which personal or sensitive information is provided, give UpdatePower adequate assurances that they will safeguard all such information in a manner consistent with both this policy and the Safe Harbor Principles.
Ability to Access and Correct Information
Upon an individual’s request, UpdatePower will provide reasonable access to any personal or sensitive information it has about that person. UpdatePower will also take reasonable steps to allow such individuals to correct, change, modify or delete any such information that is shown to be incorrect, inaccurate or incomplete.
UpdatePower will investigate any complaints about the use and disclosure of personal or sensitive information that are not in accordance with this policy. If UpdatePower is unable to informally resolve any such matter to the individual’s reasonable satisfaction, it will participate in the dispute resolution procedures of the legal or regulatory body having jurisdiction over the matter (e.g., the Federal Trade Commission), including, as appropriate, a panel established by the European Data Protection Authorities, so that disputes are resolved according to the Safe Harbor Principles.
Enforcement and Compliance
UpdatePower will conduct regular audits to monitor compliance with this policy and will provide annual certifications to the U.S. Department of Commerce that it has done so. Violations of this policy will subject the violator to disciplinary action, up to and including termination.
UpdatePower may amend or modify this policy from time to time by posting the amended or modified version on its website at www.UpdatePower.com. Amendments and modifications will be made in a manner so as to remain consistent with the Safe Harbor Principles. This policy may also be changed, or limited, to comply with legal or regulatory requirements, or as otherwise allowed or required by law.
Questions or comments about this policy, or concerns or complaints about possible violations, should be sent to:
Attention: Human Resources
900 E. Hamilton Ave. Suite 100