We are dedicated to maintaining both a high standard of privacy and a high standard of data protection in all of our activities. We must however balance our respect for the privacy interests of our customers, resellers, end-users, and employees with our public responsibilities. This is particularly true with respect to our obligations required to present contact information to authorities and third parties as required.
This policy will apply to and protect all personal information collected, used or disclosed by us, except information that is aggregated in such a manner that it cannot be connected to a person and/or information which is publicly available.
Personal information which may fall under the policy may include but is not limited to:
Personal information may be collected when:
However, the policy does not impose any limits on the collection, use or disclosure of the following information:
Guidelines for Internet/Website Users
There are additional guidelines that apply to persons who use websites and portals we control. In addition to the principles outlined above, we may permit third parties to offer users with subscription and/or registration-based services through sites and portals we control.
In such circumstances, we cannot be responsible for the content of any third party offerings or any actions or policies of such third parties. We also remind users that voluntarily disclosed information online in discussion areas or other public areas of our sites and portals can be collected and used by third parties and may result in unsolicited messages from third parties. Unfortunately, such activities are beyond our control.
In some cases, users’ non-personal information and data may be automatically collected through the standard operation of our business and/or through the use of “cookies”. “Cookies” are small text files that may be used by us to:
(a) recognize repeat users;
(b) track usage behavior; and
(c) compile aggregate data that will permit content improvements and targeted advertising.
However, cookies may be required for the use of certain features on our sites and portals. Any submissions made to discussion areas or other public areas on our sites and portals are done so with a user’s understanding that they are accessible to third parties.
If comments are not intended for third parties, you are advised not to make any submissions. In any event, users can request that we cease from sending advertising from us or our authorized agents at any time by simply contacting us.
Our policy generally and in connection with our business use is subject to the requirements or provisions of any applicable legislation, regulations or agreements, or order of any court, or other lawful authority.
Your use of our sites and portals is also subject to these requirements.
THE PRIVACY PRINCIPLES WE FOLLOW
There are ten principles, which form the basis of our policy. These principles are interrelated and we shall adhere to them as a whole. Each principle must be read in conjunction with the accompanying commentary. The commentary in our policy may be tailored to reflect personal information issues specific to us.
To better understand our policy, we have set out some basic definitions to use when reading and interpreting the principles below:
Collection – the act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
Consent – voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on our part. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction. Consent will be implied when an individual or entity applies to receive information or services and agrees to the general terms and conditions imposed by us and/or our applicable partner or partners.
Customer – an individual or entity that uses, or applies to use, our products or services, including but not limited to both affiliates and customers.
Disclosure – making personal information available to a third party.
Personal information – information about an identifiable individual that is recorded in any form, but does not include aggregated information that cannot be associated with a specific customer. For a customer, such information does not include information that is aggregated in such a manner that it cannot be connected to him/her and/or information which is publicly listed in a written or online directory.
Third party – an individual or organization outside our business.
Use – the treatment, handling, and management of personal information by and within our business.
Principle 1 – Accountability
We shall implement policies and practices to give effect to these principles, including:
Principle 2 – Identifying Purposes for Collection of Personal Information
We shall identify the purposes for which personal information is collected at or before the time the information is collected.
Further references to “identified purposes” mean the purposes identified in this Principle 2 – A.
2. Unless the purpose is implied from the nature of the service provided, we shall specify orally, electronically or in writing the identified purposes to the customer or employee at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within our company who shall explain the purposes.
3. Unless required by law, we shall not use or disclose for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the customer.
Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a customer is required for the collection, use, or disclosure of personal information, except where inappropriate.
NOTE: In certain circumstances personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate when the individual is a minor, seriously ill, or mentally incapacitated. In addition, if we do not have a direct relationship with a customer, we may not always be able to seek consent.
Principle 4 – Limiting Collection of Personal Information
We shall limit the collection of personal information to that which is necessary for the identified purposes. We shall collect personal information by fair and lawful means.
Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
We shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by an authority or by law. We shall retain personal information only as long as necessary for the fulfillment of those purposes or as required by law.
1. We may disclose a customer’s personal information to:
2. Only our employees with a business need to know, or whose duties reasonably so require, are granted access to personal information that is not publicly available about customers.
3. We shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer, we shall retain, for a period of time that is reasonably sufficient to allow for access by the customer, either the actual information or the rationale for making the decision.
4. Personal information that is no longer necessary or relevant for the identified purposes or required to be retained by law shall be destroyed, erased or made anonymous. In any event, we shall maintain reasonable and systematic controls, schedules and practices for such information, its retention and destruction.
Principle 6 – Accuracy of Personal Information
Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
Principle 7 – Security Safeguards
We shall protect personal information by security safeguards appropriate to the sensitivity of the information.
Principle 8 – Openness Concerning Policies and Practices
We shall make readily available to customers and employees specific information about our policies and practices relating to the management of personal information.
1. We shall make information about our policies and practices easy to understand, including:
Principle 9 – Customer Access to Personal Information
We shall inform a customer of the existence, use, and disclosure of his or her personal information upon request and shall give the individual access to that information. A customer shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain situations, we may not be able to provide access to all of the personal information we hold about a customer. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons or information that is subject to solicitor-client or litigation privilege. We shall provide the reasons for denying access upon request.
Principle 10 – Challenging Compliance
A customer shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for our compliance with the policy.
For more information, please contact us through our business address as follows:
SearchLab Chicago Inc.
1801 W Belle Plaine Ave
Chicago, IL 60613 USA
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