Safe Harbor Policy
Arsenal Security Group and its subsidiary companies recognize that privacy is very important to our customers and employees, and therefore strives to protect the personal information it collects and handles. This Policy sets forth the privacy principles that Arsenal Security Group follows with respect to transfers of personal information from the EU to the US.
Scope
This Policy applies to all personal information received by Arsenal Security Group from the EU. Such personal information may pertain to Arsenal Security Group EU employees. It may also pertain to third party individuals in connection with Arsenal Security Group providing technical and solutions support to Arsenal Security Group, EU-based clients, or clients in possession or control of personal information in the EU.
Definitions
The following definitions shall apply throughout this Policy:
"Agent" means any third party that uses personal information provided to Arsenal Security Group to perform tasks on behalf of and under the instructions of Arsenal Security Group.
“EU” means the European Union, including its member states.
"Personal information" means any information or set of information that identifies an individual, or could be used by or on behalf of Arsenal Security Group to identify an individual.
“Policy” means this Safe Harbor Policy.
"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual’s health or sex life. In addition, Arsenal Security Group will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
“US” means the United States and its territories.
Privacy Principles
The privacy principles in this Policy are based on the Safe Harbor Privacy Principles.
Notice
When Arsenal Security Group collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses their personal information, the types of non-agent third parties, if any, to which Arsenal Security Group discloses that information, and the choices and means, if any, that Arsenal Security Group 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 Arsenal Security Group, or as soon as practicable thereafter, and in any event before Arsenal Security Group uses the information for a purpose other than that for which it was originally collected.
If Arsenal Security Group receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices such entities provided and the consents or choices made by the individuals about whom such personal information relates.
Choice
Arsenal Security Group will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party (unless allowed or requited by contract), 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, Arsenal Security Group will give individuals the opportunity to affirmatively and explicitly consent (e.g., through an opt-in) 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. Arsenal Security Group will provide individuals with reasonable methods to exercise their choices.
If you choose not to provide the personal information we request, you can still visit most of Arsenal Security Group’s web sites, but you may be unable to access certain options, offers and services that involve our interaction with you.
If you chose to have a relationship with Arsenal Security Group, such as a contractual or other business relationship or partnership, we will in the course of conducting business continue to contact you in connection with that business relationship.
Data Integrity
Arsenal Security Group will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Arsenal Security Group will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. Arsenal Security Group provides our customers with the capability to correct the information that we obtain from you.
Onward Transfer
Arsenal Security Group will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. If Arsenal Security Group has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Arsenal Security Group will take reasonable steps to prevent or stop the use or disclosure.
Access
Upon request, Arsenal Security Group will grant individuals reasonable access to personal information that it holds about them, and Arsenal Security Group provides our customers with reasonable access to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
Security
Arsenal Security Group will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Enforcement
Arsenal Security Group will conduct compliance reviews of its relevant privacy practices to verify adherence to this Policy. Any employee that Arsenal Security Group determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
Dispute Resolution
Any questions or concerns regarding the use or disclosure of personal information should be directed to Arsenal Security Group at the email and mailing addresses given below. Arsenal Security Group 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. For complaints that cannot be resolved between Arsenal Security Group and the complainant, Arsenal Security Group has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.
Contact Information
Questions or comments regarding this policy should be submitted to:
Arsenal Security Group
1600 Tysons Blvd. 8th Floor,
McLean, VA 22102
703-986-1700 x8615
asginfo@arsenalsecuritygroup.com
Please include your name, address, and phone number or email in all communications and clearly state the nature of your request.
Changes to this Policy
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 such changes.
Limitation on Application of Principles
Adherence by Arsenal Security Group to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation, and (b) to the extent permitted by applicable law.
Effective Date: April 5th, 2009
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