Personal data transferred from the European Economic Area ("EEA")1 to the United States of America ("U.S.")
3. Definitions For purpose of this Policy, the following definitions shall apply: "Agent" means any third party that collects and/or uses personal information provided by Alpha to perform tasks on behalf of and under the instructions of Alpha. "Personal information" means any information relating to an identified or identifiable person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Personal information does not include information that is anonymous and/or statistical. "Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or that concerns health matters or sexual orientation.
1 The EEA currently includes the following countries: Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovak Republic, Slovenia, Spain, Sweden, United Kingdom, Iceland, Liechtenstein, and Norway. 2 Information about the U.S. Department of Commerce Safe Harbor certification can be found atwww.export.gov/safeharbor.
4. Processing of EEA personal data Alpha may from time to time process certain EEA personal information about customers, business partners, employees and candidates for employment, including information recorded on various media as well as electronic data. Alpha will use personal information concerning business partners and customers to provide customers and business partners with information and services and to help Alpha personnel better understand the needs and interests of these business partners and/or customers. Specifically, Alpha uses information to help customers and business partners complete a transaction or order, to facilitate communication, to deliver products/services, to bill for purchased products/services, and to provide ongoing service and support. Occasionally Alpha personnel may use personal information to contact customers and business partners to complete surveys that are used for marketing and quality assurance purposes. Alpha may also share personal information with its service providers and suppliers for the sole purpose and only to the extent needed to support the customers’ business needs. Service providers and suppliers are required to keep confidential personal information received from Alpha and may not use it for any purpose other than as originally intended. Alpha also collects personal information concerning its employees (Human Resources Data) in connection with administration of its Human Resources programs and functions and for purpose of communicating with its employees. These programs and functions may include compensation and benefit programs, employee development planning and review, performance appraisals, training, business travel expense and tuition reimbursement, identification cards, access to Alpha facilities and computer networks, employee profiles, internal employee directories, Human Resource record keeping, and other employment related purposes. Alpha also collects and uses personal information to consider candidates for employment opportunities within Alpha. Human Resources data may be shared with third party vendors for the exclusive purpose of enabling the vendor to provide service and/or support to Alpha in connection with these Human Resource programs and functions. Human Resource data is not shared with third parties for non-employment related purposes. Third parties receiving personal information are required to apply the same level of privacy protection as contained in this Policy.
6. Dispute Resolution Any questions or concerns regarding the use or disclosure of personal information should be directed to The Group Legal Adviser and Compliance Officer for Safe Harbor at the address given below. Alpha 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. With respect to any complaints relating to this Policy that cannot be resolved through Alpha’s internal processes, Alpha has agreed to participate in the dispute resolution procedures of the Panel established by the EU Data Protection Authorities to resolve disputes pursuant to the Safe Harbor principles. In the event that Alpha or such Authorities determines that Alpha did not comply with this Policy, Alpha will take appropriate steps to address any adverse effects and to promote future compliance.
7. Targeting Minors Alpha does not knowingly collect personally identifiable information from persons under the age of 13. If for some reason Alpha determines that a person with respect to whom it has collected personal information is under 13, Alpha will promptly delete or destroy that information.
8. Contact Information Questions or comments regarding this Policy should be submitted to Alpha by mail or e-mail as follows:
The Group Legal Adviser and Compliance Officer for Safe Harbor firstname.lastname@example.org
9. 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 amendments. This policy builds on the principles set out in the Alpha Code of Conduct and in particular the Company’s commitment to high standard of professionalism, behavior and respect for the dignity of individuals.
Effective Date: 1 October 2007