PRIVACY POLICY

Last Modified: November 2013

A. ADPC’s Commitment to Privacy

ADPC Inc., (“ADPC”) and its affiliates created this privacy statement (“Statement”) in order to demonstrate our commitment to your customer privacy.  ADPC and its affiliates provide a variety of information, Internet, network, security, and technology related services (“Services”).  Privacy on ADPC web site (the “Site”) properties is of great importance to us. Because we gather important information from our visitors and customers, we have established this Statement as a means to communicate our information gathering and dissemination practices. We reserve the right to change this Statement and will provide notification of the change at least thirty (30) business days prior to the change taking effect.

B. Safe Harbor Compliance

ADPC has certified its participation, and compliance with, the U.S. Department of Commerce Safe Harbor framework regarding the transfer of personal information from European Union member countries to the United States. The principles of Safe Harbor compliance are notice, choice, onward transfer, security, data integrity, access, and enforcement. Additional information about the Safe Harbor principles and certification process can be found at www.export.gov/safeharbor. We are a self-certifying member of the U.S.-European Union and the U.S.-Switzerland Safe Harbor Frameworks and adhere to the Safe Harbor Privacy Principles.

Details of our registration can be found here: ADPC’s Safe Harbor Company Profile. Under the laws of the United Kingdom, we are a “data controller” in respect of the personal Information of our members but not in respect to people in your Services account (the “Data”) where we act as a “data processor.”

C. Personal Information We Collect

Personal Information is information that identifies or can identify a specific individual. ADPC may collect information about individuals such as their name, address, telephone number or e-mail address. ADPC may collect certain personal information from customers, business partners, employees and candidates for employment. ADPC does not collect personal information when you visit ADPC’s web sites unless you choose to provide it to ADPC.

Customers and Business Partners — On ADPC web sites you can order products or services, register products, request information, subscribe to marketing or support materials, register to a secure extranet site to obtain access to product information, support, services, and training. ADPC will collect personal information from you for these purposes. The types of information you provide to ADPC on these pages may include name, address, phone number, e-mail address, user IDs and passwords, billing and transaction information, credit card or other financial information, and contact preferences.

Employees and Applicants — ADPC also collects personal information from its employees and applicants (human resources data) in connection with its recruiting and hiring activities and administration of its human resources programs and functions. Current ADPC employees can go on-line to access their individual employee profiles, job data, compensation, benefit information, and to make benefit elections and transactions or to make changes to their personal information.

D. Use and Disclosure of Your Information

ADPC will use personal information to provide customers and business partners with information and services and to help us better understand your needs and interests. Generally, we use your information to help you complete a transaction or order, to communicate with you, to deliver products/services to you, to bill you for products/services you purchased, and to provide ongoing service and support. Occasionally we may use your information to contact you to complete surveys that we use for marketing and quality assurance purposes. Personal information collected online may be combined with information you provide to ADPC through other sources such as trade shows or seminars. We may also use it to contact you by electronic or other means such as telephone or mail, to tell you about products and services of ADPC or its subsidiaries and divisions, or, if we think this may interest you or other parties.

Except as we explicitly state at the time we request information, or as provided for in the ADPC Software End User License Agreement, we do not disclose to third parties the information provided. ADPC will use and disclose your Information and Data only as follows:

  1. To set up the Service and promote continued use of the Service. We use your Information to set up the Service for you and your organizations. We may also use the Information to contact customers to further discuss customer interest in our company, the Service that we provide, and to send information regarding our company or partners, such as promotions and events. Customers are invited to receive an email newsletter by providing an email address. Customer email addresses and any personal customer information will not be distributed or shared with third parties. Customers can opt out of being contacted by us, or receiving such information from us, at any time by sending an email to REPRESENTATIVE. Separately, customers are also asked to provide an email address when registering for the Service, in order to receive a username and password. We may also email information regarding updates to the Service or company.
  2. To send you messages about the Service to let you know about temporary or permanent changes to the Service including planned outages, new features offered, version updates, abuse warnings, changes to our Privacy Policy and other documents and agreements.
  3. To bill and collect sums owed to us. All financial and billing information that we collect through the Site is used solely to check the qualifications of prospective customers and to bill for the Service. This billing information is not used by ADPC for marketing or promotional purposes. ADPC uses a third-party intermediary to manage our credit card processing. This intermediary is solely a link in the distribution chain, and is not permitted to store, retain, or use the information provided, except for the sole purpose of credit card processing.
  4. To help enforce compliance with our ADPC End User License Agreement (EULA).
  5. To protect the rights and safety of our company, our employees, our members and users and to meet legal requirements such as complying with court orders and valid subpoenas. ADPC reserves the right to share your Information to respond to duly authorized information requests of governmental authorities or where required by law. In exceptionally rare circumstances where national, state or company security may be at issue, ADPC reserves the right to share our entire database with appropriate governmental authorities.
  6. To communicate with you concerning your account.
  7. To transfer your Information in the event of a sale of substantially all of the assets of our business to a third party or in the event of a merger, consolidation or acquisition. However, in any such event, the acquirer will be subject to our obligations under this Privacy Policy.
  8. Refer a friend. If you elect to use our referral service for informing a friend about our site, we ask you for your friend’s name and email address. ADPC Software will automatically send the friend a one-time email inviting them to visit the site. We do not retain or store this information.
  9. Some of ADPC Sites make on-line newsgroups, chat forums and blogs available to our users. Any information that is disclosed in these forums becomes public information and you should exercise caution when deciding to disclose your personal information. ADPC may, from time to time, send e-mail (in accordance with applicable laws) regarding our products and services to users who have posted to our newsgroups. Each participant’s opinion expressed in a newsgroup is his or her own and should not be considered as reflecting the opinion of ADPC. Some ADPC Sites also provide for “Live Chat” wherein ADPC personnel can monitor the user’s areas of interest in the web site and engage in instant messaging with the user to provide additional information or answer any questions. By posting in our newsgroups and using “Live Chat” you expressly consent to these uses of your information.

E. Employee and Job Applicant Data

ADPC uses personal information of its employees, contractors, and job applicants for a variety of human resources and similar functions, including job applications and hiring programs, compensation and benefit programs, performance appraisals, training, business travel, expense and tuition reimbursement, identification cards, access to ADPC facilities and computer networks, employee profiles, internal employee directories, human resources recordkeeping, compliance with legal requirements and other employment related purposes.

Unless permitted by relevant laws, or you have agreed to this, ADPC does not use your personal information for a purpose other than as provided in this Privacy Statement or for the stated purpose identified at the time such information is collected, received or stored. Where appropriate under applicable laws, you will be given a more detailed explanation of these data uses at the relevant time.

Personal information given to ADPC may be transferred within ADPC or to its appointed business partners or service providers across state and country borders for efficient data consolidation, storage and simplified information management in accordance with applicable law. We will place appropriate restrictions on the recipients and require them to adequately protect the information according to relevant laws.

F. Third-Party Sites

ADPC contracts with third party service providers and suppliers to deliver complete products, services and customer solutions. ADPC may 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 and secure the personal information received from ADPC and may not use it for any purpose other than as originally intended.

Human resources data may be shared with third party vendors for the exclusive purpose of enabling the vendor to provide service or support to ADPC in connection with these human resources programs and functions. Personal data concerning ADPC employees is not shared with third parties for non-employment related purposes, unless disclosure of such information is reasonably necessary to comply with any applicable law, legal process, or enforceable governmental inquiry.

Third party vendors, service providers and suppliers receiving personal information are expected to apply the same level of privacy protection as contained in this Privacy Statement. However, unless otherwise dictated by law or agreement, ADPC is not responsible for any improper use by such parties.

Unless permitted by relevant laws, or you have agreed to this, ADPC will not share personal information you provided to ADPC with any other third parties without your permission, or sell, trade or lease your personal information to others, except as provided in this Privacy Statement.

G. Links to Non-ADPC Sites and Third Parties

ADPC Sites may provide links to third-party websites for your convenience and information. If you access those links, you will leave the ADPC Site. ADPC does not control those sites or their privacy practices, which may differ from ADPC’s. We do not endorse or make any representations about third party websites. The ADPC Privacy Statement does not cover the personal data you choose to give to unrelated third parties. We encourage you to review the privacy policy of any company before submitting your personal information.

H. Sensitive Information

Sensitive information is defined as personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of the individual.

Except as provided below, ADPC does not request or receive sensitive information from visitors to our web sites. ADPC may receive sensitive information such as medical or health conditions, or race and ethnic data regarding its employees or their dependents in connection with the administration of its health and welfare benefit plans, or as part of government mandated recordkeeping requirements where required by law. Such information will not be shared with third parties except as permitted by applicable law or as required in connection with the administration of human resources programs. In addition, sensitive information that has not been made public by an affected employee will not be used for a purpose other than its original purpose without the employee’s approval unless allowed under applicable law. Where appropriate under applicable laws, you will be given a more detailed explanation of sensitive information uses at the relevant time.

I. Accuracy of Personal Information

ADPC strives to keep your personal information accurate. We have implemented technology, management processes and policies to maintain data integrity. ADPC will take reasonable steps to ensure that the data is complete, accurate and reliable for its intended use. We will provide you with access to your information when reasonable, or in accordance with relevant laws, including making reasonable effort to provide you with online access and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making changes to your data. Requests to delete personal data are subject to any applicable legal and ethical reporting or document retention obligations.

J. Security

ADPC is committed to taking reasonable efforts to secure the personal data you choose to provide us. To protect the privacy of any personal information you may have provided, ADPC employs industry-standard controls including physical and logical access controls, Internet firewalls, intrusion detection, anti-virus protection, and network monitoring, and, where appropriate, Secure Socket Layer (SSL) or similarly encrypted browsers. In addition, access to sensitive information as defined in this Privacy Statement is limited to those individuals and agents having a need to know. Finally, ADPC Software provides unique user names and passwords that must be entered each time a customer logs on. These safeguards help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of Data.

K. Opt-Out Policy

ADPC Software offers its visitors and customers a means to choose how we may use information provided. If, at any time after registering for information or ordering the Service, you change your mind about receiving information from us or about sharing your information with third parties, send us a request specifying your new choice. Simply send your request to REPRESENTATIVE.

L. Correcting & Updating Your Information

If customers need to update or change registration information they may do so by editing the user or organization record. To update a User Profile, log on to ADPC Software and select User Profile to add or update information. To update Organization’s data, log on to ADPC Software and select Organization Setup. To update billing information please email our REPRESENTATIVE or call 1-888-262-2808. ADPC Software will respond to your correction or update request within at most 30 days from the date of your request.

M. Dispute Resolution

If an employee has a complaint regarding the transfer of human resources data to the U.S., ADPC agrees to cooperate with the appropriate data protection authority for handling such complaints. ADPC agrees to handle all other disputes involving the transfer of personal data in accordance with applicable law.

N. Contact Information

If you have any questions or comments regarding this Privacy Statement or believe that the privacy of your personal information has not been respected, you may make a written submission to the attention of ADPC’s Office of the General Counsel, at 116 Village Blvd., Suite 200 Princeton, NJ, USA, 08540.

O. Verification

ADPC will engage in periodic self-assessment to verify that it continues to be in compliance with this Privacy Statement.

(End – Privacy Policy)