Your privacy is important to us. To better protect your privacy we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this policy easy to find, we make it available on our homepage and at every point where personally identifiable information may be requested.
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the "U.S.-EU Safe Harbor"). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the "U.S.-Swiss Safe Harbor"). Consistent with its commitment to protect personal privacy, Attracta adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the "Safe Harbor Principles").
This Policy applies to all personal information received by Attracta in any format, including electronic, paper or verbal.
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, Attracta or to which Attracta discloses personal information for use on Attracta's behalf.
"Attracta" means Online Brand Builder, Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States.
"Personal information" means any information or set of information that identifies or could be used by or on behalf of Attracta 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, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Attracta will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Policy have been developed based on the Safe Harbor Principles.
Where Attracta 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 nonâagent third parties to which Attracta discloses that information, the choices and means, if any, Attracta offers individuals for limiting the use and disclosure of personal information about them, and how to contact Attracta. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Attracta, or as soon as practicable thereafter, and in any event before Attracta uses or discloses the information for a purpose other than that for which it was originally collected.
Where Attracta receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
Attracta 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, Attracta 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.
Attracta will provide individuals with reasonable mechanisms to exercise their choices.
Attracta will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Attracta will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
Transfers to Agents:
Attracta will obtain assurances from its agents that they will safeguard personal information consistently 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), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Attracta has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Attracta will take reasonable steps to prevent or stop the use or disclosure.
Access and Correction:
Upon request, Attracta will grant individuals reasonable access to personal information that it holds about them. In addition, Attracta will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
Attracta will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Attracta will conduct annual compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Attracta 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 first directed to the Attracta Privacy Office at the address given below. Attracta will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between Attracta and the complainant, Attracta has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:
- For disputes involving all personal information received by Attracta from Switzerland, Attracta has agreed to cooperate with the Swiss FDPIC;
- For disputes involving employment-related personal information received by Attracta from the EEA, Attracta has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
- For disputes involving all other personal information received by Attracta from the EEA, Attracta has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities. Individuals who submit a question or concern to Attracta and who do not receive acknowledgment from Attracta of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the European data protection authorities.
Application of Principles
The Information We Collect:
This notice applies to all information collected or submitted on the Attracta™ website. On some pages, you can order products, make requests, and register to receive materials. The types of personal information collected at these pages are:
- Email address
- Phone number
- Credit/Debit Card Information
The Way We Use Information:
We use the information you provide about yourself when placing an order or ordering service only to complete that order. We do not share this information with outside parties except to the extent necessary to complete that order.
We use return email addresses to answer the email we receive. Such addresses are not used for any other purpose and are not shared with outside parties.
When you register for service with our website you may receive email messages relating the services provided. You may also receive alerts when your service level has been exceeded.
We use non-identifying and aggregate information to better design our website and to share with advertisers. For example, we may tell an advertiser that X number of individuals visited a certain area on our website, or that Y number of men and Z number of women filled out our registration form, but we would not disclose anything that could be used to identify those individuals.
Finally, we never use or share the personally identifiable information provided to us online in ways unrelated to the ones described above without also providing you an opportunity to opt-out or otherwise prohibit such unrelated uses.
Our Commitment To Data Security:
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
Our Commitment To Children's Privacy:
Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.
How You Can Access Or Correct Your Information:
You can access all your personally identifiable information that we collect online and maintain by Attracta™.
You can correct factual errors in your personally identifiable information by sending us a request that credibly shows error.
To protect your privacy and security, we will also take reasonable steps to verify your id entity before granting access or making corrections.
Limitation on Application of Principles
Adherence by Attracta to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
Questions or comments regarding this Policy should be submitted by mail to the Attracta Privacy Office:
111 2nd Ave NE, Suite 620
St. Petersburg, FL 33701
Or by e-mail at privacy [at] attracta.com
Effective Date: November 1, 2011