European Union Safe Harbor Policy
Domino Developer Network, Inc. ("the
company," "we,"
"us," or "our") respects
individual Privacy and values the confidence
of our customers, employees, consumers,
business partners, and others. Domino
Developer Network adheres to the Safe Harbor
Agreement concerning the transfer of
personal data from the European Union or
‘Commonwealth’ to the United States of
America. Accordingly, we follow the Safe
Harbor Principles published by the U.S.
Department of Commerce
("Principles") with respect to all
such data. This statement outlines our
general policy and practices for
implementing the Principles, including the
types of information the company gathers,
how we use it, and the choices affected
individuals have regarding our use of, and
their ability to correct, that information.
This statement applies to all personal
information we handle, including on-line
(except as noted below), off-line, and
manually processed data. For purposes of
this statement, "personal
information" means information that:
• is transferred from the European Union to the United States
• is recorded in any form
• is about, or pertains to, a specific individual or can be linked to that individual
Principles Protecting Individuals' Privacy
Notice and Choice
To the extent permitted by the Safe Harbor
Agreement, we reserve the right to process
personal information in the course of our
internal business operation without the
knowledge of individuals involved.
Where the company receives personal
information from its subsidiaries,
affiliates, or other entities in the EU, the
company will use and disclose such
information in accordance with the purposes
for which it was originally collected, or in
accordance with the notices provided by such
entities.
The company will provide notice and provide
individuals with an opportunity to "opt
out" if such personal information is to
be disclosed to a third party or used for a
purpose incompatible with the purpose for
which it was originally collected. For
sensitive information, affirmative or
explicit, the company will provide notice
and individual choice will be given to
"opt-in" if such sensitive
information is to be disclosed to a third
party or used for a purpose other than the
purpose for which it was originally
collected.
We collect personal information from
individuals only as permitted by the
Principles or with the consent of the
individual affected. Consent for personal
information to be collected, used, and/or
disclosed in certain ways may be required in
order for an individual to obtain or use our
services.
Disclosures and Transfers
We do not disclose an individual's personal
information to third parties, except when
one or more of the following conditions is
true:
• We have the individual's permission to make the disclosure
• The disclosure is required by law or mandatory professional standards
• The disclosure is reasonably related to the sale or other disposition of all or part of our business
• The information in question is publicly available
• The disclosure is reasonably necessary for the establishment of legal claims
• The disclosure is to another Domino Developer Network entity or to persons or entities providing services on our or the individual's behalf (each a "transferee"), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
• is subject to law providing an adequate level of privacy protection
• has agreed in writing to provide an adequate level of privacy protection
• subscribes to the Principles
Permitted transfers of information, either
to third parties or within Domino Developer
Network, or between subsidiaries of Domino
Developer Network, include the transfer of
data from one jurisdiction to another,
including transfers to and from the United
States of America. Because privacy laws vary
from one jurisdiction to another, personal
information may be transferred to a
jurisdiction where the laws provide less or
different protection than the jurisdiction
in which the information originated.
Data Security, Integrity and Access
We employ various physical, electronic, and
managerial measures, designed to provide
personal information with reasonable
protection from accidental loss or
destruction, improper use, alteration, or
disclosure. However, we cannot guarantee the
security of information on or transmitted
via the Internet.
We process personal information only in ways
compatible with the purpose for which it was
collected or authorized by the individual.
To the extent necessary for such purposes,
we take reasonable steps to make sure that
personal information is accurate, complete,
current, and otherwise reliable with regard
to its intended use.
If an individual becomes aware that
information we maintain about that
individual is inaccurate, or if an
individual would like to update or review
his or her information, the individual may
contact us using the contact information
below. The individual will need to provide
sufficient identifying information. We may
request additional identifying information
as a security precaution. In addition, we
may limit or deny access to personal
information where providing such access
would be unreasonably burdensome or
expensive in the circumstances, or as
otherwise permitted by the Safe Harbor
Agreement. In some circumstances, we may
charge a reasonable fee, where warranted,
for access to personal information.
Information Subject to Other Policies
We are committed to following the Principles
for all personal information within the
scope of the Safe Harbor Agreement. However,
certain information is subject to policies
of the firm that may differ in some respects
from the general policies set forth in this
statement.
• Links from our external website and our
intranet have their own privacy policies
that apply to those websites. These policies
may be accessed through the websites in
question.
• Information obtained from or relating to
clients or former clients is further subject
to the terms of any confidentiality or
privacy notice to the client, any engagement
letter or service agreements executed with
the client, and applicable laws and
professional consulting standards.
Principles Protecting Individuals' Privacy
Domino Developer Network, Inc. reserves the
right to change this Privacy Policy from
time to time and will post any revisions on
this web site. When we do so we will also
revise the "last updated" date at
the end of this Privacy Policy.
Amendments
This policy may be amended from time to
time, consistent with the requirements
of the Safe Harbor Principles. If we
amend this policy, a revised policy will
be posted on our Web site.
Effective Date: 07 December 2013