Altum Safe Harbor Policy
This policy was last updated on 14th October, 2011.
Safe Harbor Policy. ALTUM is committed to protecting your privacy. ALTUM has put in place internal procedures, to ensure that your personal information is processed responsibly and in accordance with applicable data protection/privacy laws. This privacy policy (the “Policy”) sets out the privacy principles that ALTUM follows with respect to transfers of personal data from the European Economic Area (EEA) to the United States.
Safe Harbor. ALTUM complies with the US-EU Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from European Union member countries. ALTUM 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 ALTUM's certifications, please visit http://www.export.gov/safeharbor
Scope. This Policy applies to all personal information, either in electronic or paper format, received by ALTUM in the United States from the EEA in any format, including electronic, paper, or verbal.
Definitions. For the purposes of the Policy, the following definitions shall apply:
"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, ALTUM or to which ALTUM discloses personal information for use on ALTUM 's behalf.
"ALTUM" means ALTUM, Incorporated, its subsidiaries, divisions, groups and affiliates in the United States.
"Personal information" means any information or set of information that identifies or could be used by or on behalf of ALTUM to identify an individual. It does not include personal information that has been anonymized or that is publicly available, 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, or information that concerns health or sex life. In addition, ALTUM will treat as sensitive, any information received from a third party where that third party treats and identifies the information as sensitive.
Privacy Principles. The privacy principles in this Policy are based on the Safe Harbor Principles.
Notice: Where ALTUM collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which ALTUM discloses that information, and the choices and means, if any, that ALTUM offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to ALTUM, or as soon as practical thereafter, and in any event before ALTUM uses the information for a purpose other than that for which it was originally collected.
Where ALTUM receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to who such personal information relates.
Choice: ALTUM will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For sensitive personal information, ALTUM will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. ALTUM will provide individuals with reasonable means to exercise their choices.
Data Integrity: ALTUM will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. ALTUM will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and up-to date.
Transfers to Agents: ALTUM will obtain assurances from its agents that they will safeguard personal information in accordance with this policy. Where ALTUM has knowledge that an agent is using or disclosing personal information in violation of this Policy, ALTUM will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Hungary and Switzerland). Where ALTUM has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, ALTUM will take reasonable steps to prevent or stop the use or disclosure.
Access and Correction: Upon request, ALTUM will grant individuals reasonable access to the personal information it holds about them. In addition, ALTUM will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
Security: ALTUM will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Enforcement: ALTUM will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. ALTUM will take all necessary measures against any employee that ALTUM determines is in violation of this policy, including disciplinary action.
Dispute Resolution: Any questions or concerns regarding the use or disclosure of personal information should be directed to the ALTUM Global Data Protection Officer at the address given below. ALTUM 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. For complaints that cannot be resolved between ALTUM and the complainant, ALTUM has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes, pursuant to the Safe Harbor Principles.
Contact Information: Questions or comments related to this policy should be submitted to the ALTUM Global Data Protection Officer by mail as follows:
Global Data Protection Officer
ALTUM, Inc.
12100 Sunset Hills Road, Suite 101
Reston, VA 20190
+1-703-657-8299
1-877-GO-ALTUM
Privacy Policy
Altum, Inc. (“Altum”) recognizes the importance of protecting the privacy of information we may receive from visitors to our web site. You may visit the Altum site without telling us anything about yourself. If you contact us and choose to provide personally identifiable information, we will use it for the purpose for which you submitted it to us – for example, to respond to your inquiry, or to consider your qualifications for a position at Altum. We do not collect or maintain personally identifiable information for resale purposes, or, other than in connection with a proposed financing, merger or other corporate transaction, share your information with any other company or organization. In addition, we will not send unsolicited messages to users of our site. Any and all uses of personally identifiable information comply with applicable United States laws. By submitting personally identifiable information to the Altum web site, to the extent permitted by law, you waive any rights you may have under any law of any other country or region.
Personally Identifiable Information
Altum only collects personally identifiable information, such as names, addresses, e-mail addresses and the like, when voluntarily provided by a web site visitor. We will notify you as to the uses, if any, we intend to make of such information beyond responding to your inquiry. If you send a resume in response to a job opening posted on this web site, we will retain your personal information only for the purpose of filling the job opening and will not use it for any other purpose. Please note that at the present time, Altum does not employ any security devices for the transmission of resumes. If you send a resume to Altum via e-mail, you may be sending sensitive personal information via clear text that could be intercepted or read by someone outside Altum during the transmission process. Altum does not ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk.
Information Routinely Collected by Our Site Technology
IP Address. From time to time the Altum web site may be configured to collect domain information – your Internet Protocol (IP) address – as part of our analysis of the use of the web site. This data enables Altum to become more familiar with which users visit our site, how often they visit and what parts of the site they visit most often. Altum uses this information to improve our web site. The IP address does not identify you personally and is collected automatically.
Cookies. Periodically, some pages on this web site may use "cookies," which are small files that the site places on your hard drive for identification purposes. These files are used for site registration and customization the next time you visit the web site. You should note that cookies cannot be read off your hard drive. Your web browser may allow you to be notified when you are receiving a cookie, giving you the choice to accept it or not. You can also refuse all cookies by turning them off in your browser. By not accepting cookies, some pages may not fully function and you may not be able to access certain information on this web site. We do not allow other sites or third parties to access our cookies for their own purposes or to place their own cookies on you as you access the Altum web site.
Third Party Links. As a convenience, the Altum web site currently contains links to a number of sites that we believe may offer useful information. The policies and procedures posted on those sites, not the policies and procedures as described here, apply to those sites. Altum suggests checking the privacy policy on each linked site directly for information on their privacy, security, data collection and distribution policies.
Changes in this Privacy Policy. Altum will only use personally identifying information in the manner described in the version of this Privacy Policy in effect when the information was collected from you. However, we reserve the right to change the terms of this Privacy Policy at any time by posting revisions to the web site.