In the course of conducting our information
services and technology business worldwide, Netteck collects and
processes personally identifiable information of our clients,
employees, suppliers, business partners, Web site visitors and other
persons (Personal Data). Maintaining the integrity and
confidentiality of Personal Data and handling it correctly is
central to the way we conduct our business activities. This policy
describes how we handle Personal Data.
Personal Data is information that can be used
directly or indirectly to identify a living individual. Personal
Data may include sensitive categories of information, such as
information that reveals racial or ethnic origin, political
opinions, religious beliefs, trade union membership or health
(Sensitive Personal Data).
This policy applies to Netteck, LLC and any of
its subsidiaries, and is effective as of January 1, 2004. All
employees will be required to abide by this policy.
This policy is designed to protect Personal Data
under applicable law as it is currently exists. However, Netteck
realizes that this policy cannot address every potential issue and
circumstance. Therefore, we acknowledge that this policy is subject
in all respects to applicable local legal and regulatory
requirements and existing agreements and confirm that we will comply
with such requirements and existing agreements.
We will observe the privacy principles described
below of Notice, Choice/Fair Processing, Access, Security/Integrity,
Onward Transfer and Enforcement/Compliance in processing Personal
When we collect and process Personal Data about
individuals, we will make certain information available to those
individuals on a reasonable and timely basis. This information will
include what Personal Data is being collected, who is collecting it,
how and for what purposes it is being collected, how it is being
used and to whom it will be disclosed.
We will process Personal Data only with consent
or when such processing is permitted by applicable law. If we need
to process Sensitive Personal Data, we will obtain explicit consent
for such processing, unless such processing is permitted by
We will not process Personal Data in a manner
incompatible with the purposes for which it was originally collected
unless later authorized by the affected individuals or allowed by
law; we will take reasonable steps to ensure that such data is
accurate, adequate, relevant and not excessive in relation to such
purposes; and we will not keep such data longer than is necessary
for such purposes.
We will enable individuals to choose whether
their Personal Data can be disclosed to a third party for direct
We will allow individuals reasonable access to
their Personal Data to verify, correct or delete their data, where
inaccurate. We will also provide a means for individuals to exercise
all other legal rights that they may have in relation to their
Personal Data will be accessible and processed
only by (i) Netteck employees, suppliers, business partners and
others who require access for the performance of their obligations
to Netteck; (ii) any person granted access by the individual to whom
Personal Data pertains; and (iii) those otherwise authorized by law
or court order.
We will take reasonable security procedures
through appropriate technical and organizational measures to protect
against unauthorized or unlawful access or processing, disclosure,
alteration, destruction or accidental loss of Personal Data.
We will utilize reasonable means to keep Personal
Data accurate, complete and current in order to protect the quality
and integrity of Personal Data, however, we rely on individuals to
provide all relevant information and to advise us of any changes to
their Personal Data to ensure that it remains accurate, complete and
When we transfer Personal Data within Netteck or
to third parties (including our suppliers and business partners), we
will observe the privacy principles of Notice and Choice (described
above), and we will require all the recipients of such data to
provide at least the same level of protection for such data as
specified by the standards stated in this policy.
We will follow internal processes for handling
complaints regarding our management of Personal Data.
We will demonstrate our compliance with this
publishing this policy conspicuously so that it is
accessible to all interested persons
appointing and maintaining a Privacy Officer with
responsibility for developing and implementing a privacy program
implementing procedures to execute this policy in
the conduct of our business, including training our employees in
the use of such procedures and disciplining employees for
failure to comply with this policy and its procedures
at least annually, reviewing this policy to ensure
that it continues to comply with prevailing privacy standards,
current applicable law and regulations and existing agreements
Netteck Web Sites
In addition to all other Personal Data handled by
Netteck, this policy applies to Personal Data collected through
Netteck Web sites.
As a convenience to our Web site visitors, we
sometimes provide links to other Web sites. These linked sites are
not under the control of Netteck, and as such, we are not
responsible for their content.
Updating the Policy
Changes in legislation and/or our business
activities may require that this policy be updated from time to
If you have any questions or comments about this
policy or our privacy practices, please contact us.
Copyright © 2004 Netteck. All rights reserved.