Safe Harbor Privacy Policy Statement

Safe Harbor

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, Beacon adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”).

Beacon Participates in the Safe Harbor Program

Beacon is a participant in the U.S.-E.U. Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce. Beacon has certified that Beacon adheres to the Safe Harbor Privacy Principles agreed upon by the U.S. and the European Union (E.U.) and Switzerland. For more information about the Safe Harbor program and to view our certification (including the scope of data covered by our Safe Harbor certification), please visit the U.S. Department of Commerce’s Safe Harbor Web site. If you would like to contact us directly about the Safe Harbor program, please send an e-mail to Privacy@askbeacon.com. Safe Harbor Privacy Policy This Safe Harbor Privacy Policy (hereinafter the “Privacy Policy”) describes the ways in which Beacon Enterprise Solutions Group (hereinafter as “Beacon”) collects, holds, exchanges, and uses data about individual persons and companies who visit www.askbeacon.com and the Beacon SharePoint Portal facility at https://shares.askbeacon.com (collectively the “Sites”). BY USING THE SITES, YOU CONSENT TO THE COLLECTION AND USE OF INFORMATION (INCLUDING PERSONAL DATA) AS SET FORTH IN THIS POLICY. YOU ALSO ACKNOWLEDGE THAT BEACON MAY PERIODICALLY CHANGE, MODIFY, ADD OR REMOVE OR OTHERWISE UPDATE THIS PRIVACY POLICY AT OUR DISCRETION. When Beacon modifies this Policy, Beacon will give you notice of the revised Privacy Policy by posting the revised Privacy Policy on the Sites and by revising the “effective date” at the top of this Policy.

Beacon will always handle your data (as defined below) with at least as much protection as provided in the version of the Policy that was in effect at the time of collection. You are responsible for regularly reviewing the current Privacy Policy. Our Privacy Policy is located on the Sites’s homepage and is also available on any page where Personal Data (as defined below) is requested.

This Privacy Policy applies only to information Beacon collected from these Sites and does not apply to any other website or business activity of Beacon Solutions Group. At data collection points within the Sites, further explanation may be provided, where appropriate, as to the purposes for which the data will be used.

Information Beacon Collects

The term “Information” as used in this Privacy Policy refers to information such as your name, e-mail address, mailing address, telephone number, and any other information that can be used to identify you or permit us to contact you physically or online. Beacon will collect Personal Data when you request access to the Sites, exchange data or files via the Sites, send us an email or if you otherwise contact us through the Sites.

You can choose not to provide Personal Data to us. However, if you do not provide such information, you will not be able to register to use the Sites, so your ability to use the Sites will be limited to those web pages available to unregistered users of the Sites. Additionally, you will not be able to place orders on the Sites, exchange information via the Sites, nor contact us with questions via email or otherwise through the Sites.

The term “Automatic Information” is information automatically collected by our web server (which may be hosted by a third-party) that your web browser makes available whenever you visit our Sites, such as your computer’s IP address, browser type, operating system version, and information about the website that you visited before visiting the Sites). The term “Automatic Information” includes “cookies” and “tags,” each of which the Sites uses (as hereafter described). A cookie is a small text file that a website’s server places on a computer’s web browser. The cookie stores information which may be read by the website’s server about the browsing activities of the computer user on the Sites. This includes information such as pages viewed and the time of your of visit. Cookies also can be used to maintain data related to a particular individual, including passwords and session security tokens. Cookies are used as a standard practice by many sites. If you would prefer not to accept cookies from our Sites or any other site, you can modify the setting on the web browser installed on your computer. Please refer to your browser’s online help feature or the user’s manual for instructions on how to do this. If you refuse to accept cookies from the Sites, it is possible that all or some portions of the Sites may not function as intended. Beacon does not use cookies to track your web related activities beyond the domain of Askbeacon.com.

Beacon uses internet tags (also known as action tags, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by-1 GIFs) and cookies at these Sites and may deploy these tags/cookies through a third-party web analytical service partner which may be located and store the respective information (including your IP-address) in a foreign country. Beacon uses this technology to measure the visitors’ experience of the Sites and to improve our technology and service offerings. The web analytical service partner may be able to collect data about visitors to our and other sites because of these internet tags/cookies, may compose reports regarding the Site’s activity for us and may provide further services which are related to the use of the Sites and the internet. They may provide such information to other parties if there is a legal requirement that they do so, or if they hire the other parties to process information on their behalf.

Automatic Information may be tied to your Personal Data after Personal Data has been submitted and, therefore, will be treated as Personal Data to the extent it may be tied to Personal Data.

The term “Information” as used herein means, collectively, Personal Data, Automatic Information, and Electronic Files. “Information” also encompasses non-personal company data such as drawings, plans, designs, specifications, project plans and schedules, as well as other company data; some of which may be considered sensitive.

Intended Use of Information

Most of Beacon’s services offered on the Sites require you to provide us with Information (i.e. Beacon SharePoint customer portal). In these situations, if you choose to withhold any Personal Data requested by us, it will not be possible for us to grant you access to certain parts of the Sites and for us to respond to your query.

Beacon may collect and use Personal Data for any business purpose, including, but not limited to, the following: to provide you with products or services, to fill, confirm, ship and bill you for products and services you request (and notify you of your order status), to market products and services which Beacon think may be of interest to you, to respond to emails, to provide customer support; to establish your online account, or to communicate with you for other purposes which are evident from the circumstances or about which Beacon informed you when Beacon collected Personal Data from you. Beacon may, at our discretion, utilize the services of a third party or parties to perform any of the purposes described in this Section 2, subject to the other provisions of this Privacy Policy (specifically including those in Section 3 below).

You provide Automatic Information to us merely by visiting the Sites. Beacon may collect and use Automatic Information to customize your Sites experience, to generally help us learn about the usage of the Sites, to help us run and maintain the Sites, to study traffic patterns, to help us recognize visitors when they visit our Sites again, and other similar uses.

Non-disclosure of Information

Beacon respects the privacy of its personnel, customers, suppliers and affiliates; especially confidential or sensitive business Information. This Privacy Policy shall not interfere with nor take precedence over any separate non-disclosure agreement that has been entered into by Beacon and our customers, service partners, sub-contractors, or suppliers. When a conflict occurs between a separate non-disclosure agreement and this Privacy Policy, the more restrictive covenant in place at the time the Information was provided shall prevail.

Beacon will not sell to nor share Information with any outside company or third party; provided, however, that Information collected from you may be transferred to a third party in the event that the business of this site or a part of it and/or the customer data connected with it is sold, assigned or transferred, in which case the Information would remain subject to the terms of the pre-existing Privacy Policy in place at the time such Information was collected or updated. Beacon may disclose your Information to Beacon Solutions Group affiliates worldwide. All of our affiliates agree to treat your Information in accordance with this Privacy Policy or in accordance with practices at least as protective as those described in this Privacy Policy. Information may also be transferred to third parties who act for or on our behalf, for further processing in accordance with the purpose(s) for which the Information were originally collected or may otherwise be lawfully processed, such as: suppliers who deliver your order and/or provide billing services; credit card companies for payment processing; and other third parties who provide services to us and who agree to maintain the confidentiality of such information in accordance with this Privacy Policy (or a policy with terms at least as protective as those described herein). These third parties may provide a variety of services to us including, without limitation, hosting these Sites, providing technical support, processing and storing user information, updating your customer information records in our database (including both physical address and email address verification), and sending or coordinating the sending of marketing communications on our behalf. These third parties have contracted with us to only use Personal Data for the agreed upon purpose. These third parties are not authorized to: (a) sell your Information to third parties, (b) disclose your Information to third parties except as may be required by law, as permitted by us or as stated in this Privacy Policy; or (c) otherwise use your Information in a manner inconsistent with the uses described in this Privacy Policy.

Beacon may disclose Information in special cases when Beacon has reason to believe that disclosing the Information is necessary to identify, contact, or bring legal action against someone who may have breached our Terms and Conditions of Use or who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Sites, or anyone else who could be harmed by such activities. Beacon may also disclose Information when Beacon reasonably believes that the law requires it (in the US or abroad).

Right of Access, Correction and Objection

Whenever Beacon processes Information, Beacon takes reasonable steps to ensure that Information is kept accurate and up-to-date for the purposes for which it was collected. In the case of direct marketing, Beacon will provide you with a method to opt out of receiving further direct marketing materials or, if required by law, with a method to opt in. You may object to our processing of your Information on the grounds that such processing is not: (a) in conformity with the uses described in this Privacy Policy; or (b) reasonably required for our compliance with law. If you wish to contact us regarding our use of your Information or object to the processing of your Information, please email Beacon at Privacy@askbeacon.com. If you contact us, please note the name of the website where you provided your Information, as well as the specific Information you would like us to correct, update or delete plus a proper identification of you. Requests to delete Information will be subject to any applicable legal and ethical reporting or document filing or retention obligations imposed on us.

Disputes & Resolution

If Beacon cannot resolve any complaint or dispute with you regarding your Information, the dispute or complaint may be submitted to a 3rd-party mechanism for resolution. Beacon has identified the American Arbitration Association for 3rd-party mediation and then, if necessary, for binding arbitration for final resolution (in accordance with the rules of the American Arbitration Association). Information about the American Arbitration Association’s services can be found at its website at www.adr.org.

Security and Confidentiality

To ensure the security and confidentiality of Information that Beacon collects, Beacon uses data networks protected by, among other things, industry standard firewalls and password protection. Beacon takes measures reasonably designed to protect your Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. Unfortunately, information transmitted on the Internet and/or stored on systems attached to the Internet is not 100% secure. As a result, Beacon does not ensure, warrant or guarantee the security or integrity of such information. Beacon will not be responsible for disclosure of any Information due to errors in transmission or the unauthorized acts of third parties. You help to maintain the security of your Personal Data and Company Data stored in our systems by keeping your username and password confidential and protecting against unauthorized access to your password and to your computer.

Data Transfer Abroad

Beacon Solutions Group is part of a global group of affiliated companies and has data systems in different countries; some of which are operated by Beacon and some of which are operated by third parties on our behalf. Beacon may transfer your Information to one of our systems outside of your country, but in all such cases, Beacon will: (a) ensure the standards of security with respect to such systems holding your Information will equal the standards of protection as existed prior to a transfer; and (b) ensure that any affiliate to whom your Information is transferred will process the same in accordance with standards at least as protective as those set forth in this Privacy Policy.  

Links to Other Sites

While you are using these Sites, you may be linked or directed to other third party sites outside of the Sites that are beyond our control. Each of these third party sites may have a privacy policy different from ours. For example, you might click on a link or banner ad that will take you off the Sites. These links and banners may take you to sites of advertisers, sponsors and co-branding partners. Please review the privacy policies of these sites. Beacon is not responsible for any actions or policies of such third parties.

Choices Available to You

As discussed above, you can always choose not to provide Information, even though it might be needed to access the Beacon SharePoint Customer Portal or needed by Beacon to perform services or provide product.

The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the Web site of its manufacturer. However, because cookies allow you to take advantage of some of the Sites’s essential features, Beacon recommend that you leave them turned on. If you block or otherwise reject our cookies, you may not have access to important portal functions.

Contact Us

If you have any queries or complaints about our compliance with this Privacy Policy, or if you would like to make any recommendations or comments to improve the quality of our Privacy Policy, please email Privacy@askbeacon.com.

EFFECTIVE DATE: July 23, 2012