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Safe Harbor Compliant
Privacy Policy

Safe Harbor Privacy Policy

Successful Channels respects individual privacy and values the confidence of its customers, employees, , business partners and others. Not only does Successful Channels strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles Successful Channels follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway).

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 " Safe Harbor Principles"). The EEA also has recognized the Safe Harbor Principles as providing adequate data protection (OJ L 45, 15.2.2001, p.47). Consistent with its commitment to protect personal privacy, Successful Channels adheres to the principles set forth in the Safe Harbor Principles.

Successful Channels complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Successful Channels has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Successful Channels’s certification, please visit http://www.export.gov/safeharbor/.

Scope

This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by Successful Channels in the United States from the EEA, in any format, including electronic, paper or verbal.

Definitions

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, Successful Channels or to which Successful Channels discloses personal information for use on Successful Channels' behalf.

"Successful Channels" means Successful Channels Incorporated, its predecessors, successors, affiliates, 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 Successful Channels 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 healthcare, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Successful Channels will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Successful Channels Privacy Principles

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

Summary

  1. Notice: Informs app users about purpose of data collected and if it is shared for any purpose
  2. Choice: Any app user is provided the option to opt out
  3. Data Integrity: Only relevant data collected and will be complete
  4. Transfers to Agents: If any data transfers happen, Successful Channels will only do with compliant agents

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