Privacy Statement

 

Strategic Programs, Inc. (“we,” “us” or “our”) is committed to protecting the privacy of companies and individuals that experience our research, consulting and other related services.  As such, we follow the Safe Harbor Principles published by the Department of Commerce relating to the collection, use, and storage of personal information from citizens of Switzerland and European Union member countries. To learn more about the Safe Harbor program, and to view Strategic Programs’ certification, please visit http://www.export.gov/safeharbor/.

 

1. Notice

Where Strategic Programs, Inc. collects personal information on Swiss or EU citizens relating to our partnership with companies employing Swiss or EU citizens, we will inform them about the purposes for which we collect and use their personal information, how to contact us with any inquiries or complaints, the types of non-agent third parties to which we disclose that information, and the choices and means Strategic Programs, Inc. offers individuals for limiting the use and disclosure of their personal information.  Notice will be provided in clear and conspicuous language at the time of collection, or as soon as practicable thereafter, and in any event before Strategic Programs, Inc. uses the information for a purpose other than that for which it was originally collected.

Where Strategic Programs, Inc. receives personal information from entities in Switzerland or the EU, it will use such information in accordance with the notices provided by such entities.

 

2. Choice

Where Strategic Programs, Inc. collects personal information on Swiss or EU citizens, we will offer the opportunity to choose (opt-out) whether their personal information is to be disclosed to a non-agent third party or to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.  Strategic Programs, Inc. will provide individuals with reasonable mechanisms to exercise their choices.  Strategic Programs, Inc. does not collect sensitive information from Swiss or EU citizens, including 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.

 

3. Onward Transfer

We will not share with, sell, transfer or disclose your personal information to third parties with the following exception(s):

      1. Disclosure of information is required by law
      2. We have your permission to do so
      3. Disclosure is to an entity providing services on our behalf and usage of the information is consistent with the purpose for which it was obtained.  Any entity receiving personal information must specify in writing that it provides the same level of protection as Strategic Programs, Inc., is subject to EU Directive 95/46/EC (the EU Data Protection Directive), is Safe Harbor certified, or is subject to another European Commission adequacy finding.

Strategic Programs, Inc. will not share personal information to third parties for uses other than originally intended.  Where Strategic Programs, Inc. gains knowledge that a third party is using or disclosing personal information contrary to our policy, Strategic Programs, Inc. will take reasonable steps to prevent or stop its use or disclosure.

 

4. Security

Strategic Programs, Inc. will take reasonable precautions to protect personal information in our possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

 

5. Accuracy

Upon request, Strategic Programs, Inc. will grant Swiss or EU citizens reasonable access to their personal information in our possession.  Strategic Programs, Inc. will take reasonable steps to permit Swiss or EU citizens to correct, amend or delete information that is demonstrated to be inaccurate or incomplete.

 

6. Enforcement and Dispute Resolution

Strategic Programs, Inc. will utilize procedures to verify compliance of and adherence to its relevant privacy practices and policy. It is every employee’s responsibility to comply with privacy policy and practices.  Any employee that we determine is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

Strategic Programs, Inc. is committed to resolving complaints about your privacy relating to the collection and use of your personal information.  Swiss or European Union citizens may contact us with privacy inquiries or complaints at:

Alex Sward
Vice President of Operations
600 S. Cherry St. Suite 400
Denver, Co 80246
1 (800) 800-5476 ext. 314
privacy@strategicprogramsinc.com
www.strategicprogramsinc.com

Should you not receive timely acknowledgement of your complaint, or if we are unable to satisfactorily address your complaint, Strategic Programs, Inc. utilizes an independent third party dispute resolution service operated by the Council of Better Business Bureaus.  Strategic Programs, Inc. agrees to cooperate and comply with the BBB.  You may contact the BBB EU Safe Harbor program at:

Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor
Web: http://www.bbb.org/us/safe-harbor-complaints

 

Changes to Privacy Policy
This policy may be amended from time to time to remain consistent with the requirements of the Safe Harbor Principles.  Any updates will be provided on our website.