Privacy Policy

Our Commitment to Privacy

Welcome to the Web site of TERIS. The privacy of our visitors is critically important to us. To better protect your privacy we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used.

The Information We Collect

This notice applies to all information collected or submitted on the TERIS Web site. For each visitor to our Web page, our Web server does not automatically recognize any information regarding the domain or e-mail address. We collect only the e-mail addresses of those who communicate with us via e-mail or voluntarily opt-in to subscribe to our newsletter.

TERIS may use cookies to collect statistics about the behavior of visitors to our Web site. However, we will not disclose personally-identifying information and will use this aggregate information only for tracking and statistics to improve the content and function of our Web site.

How TERIS Uses Information

You can register with our Web site if you would like to receive our e-mail newsletter, as well as updates on our new products and services. Information you submit on our Web site will not be used for this purpose unless you fill out the subscription form.

We use return e-mail addresses to answer the e-mail we receive. Such addresses are not used for any other purpose and are not shared with outside parties.

Finally, we never use or share the personally identifiable information provided to us online in ways unrelated to the ones described above without also providing you an opportunity to opt-out or otherwise prohibit such unrelated uses.

Commitment to Data Security

We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you at our site. If you feel that this site is not following its stated information policy, you may contact us at the addresses or phone number below.

Accessing or Correcting Your Information

Upon request we provide site visitors with access to all personally identifiable information that we maintain about them. Consumers can access this information or have this information corrected by e-mailing or writing to us. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.

If you do not want to receive e-mail from us in the future, please let us know by sending us e-mail to the address below or writing to us at the postal address below.

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future, we will post the policy changes to our Web site to notify you of these changes and provide you with the ability to opt out of these new uses. If you are concerned about how your information is used, please check back at our Web site periodically to review updates to our privacy policy.

Customers may prevent their information from being used for purposes other than those for which it was originally collected by e-mailing us at the address below or writing to us at our postal address.

Contacting Us

If you have other questions or concerns about the TERIS Web site privacy policy, please contact us at the postal mail address, e-mail address or phone number below:

Our postal address is:
1001 4th Ave, Suite 2110
Seattle, WA 98154

We can be reached via e-mail at seattle(at)TERIS.com or by telephone at 206.521.8717.

Effective April 2010

Safe Harbor Data Privacy Policy

TERIS respects individual privacy and values the confidence of its customers, their stakeholders, employees, business partners and others who may use our services. Not only do we strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which we do business, but we also aim to uphold the highest ethical standards in our business practices. This Privacy Policy sets forth the privacy principles that TERIS follows with respect to the protection and transfers of personal information, whether it is in electronic, paper or verbal format, between the United States and member states of the European Union, Iceland, Liechtenstein and Norway (the European Economic Area). This statement applies to all personal information we handle (except as noted below), including on-line, off-line, and manually processed data.

SAFE HARBOR

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. companies to satisfy European Union law requirements for adequate protection of personal information transferred from the EU to the United States. The EEA also has recognized the U.S. Safe Harbor as providing adequate data protection. Consistent with its commitment to protect personal privacy, TERIS adheres to the Safe Harbor Principles.

DEFINITIONS

"TERIS" means TERIS, its predecessors, and successors.

Personal information" means any information or set of information that identifies or could be used by TERIS, its customers or agents of its customers, to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information. It does not include information that pertains to a specific individual, but from which that individual could not reasonably be identified.

Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, TERIS will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The following privacy principles are based on the Safe Harbor Principles.

Notice and Choice

To the extent permitted by the Safe Harbor Agreement, TERIS reserves the right to process personal information in the course of providing professional services to our clients without the knowledge of individuals involved. Where we collect personal information directly from individuals in the E.U., we inform them about the types of personal information we collect from them, the purposes for which we collect and use it, and the types of non-agent third parties to which we disclose that information. We also inform those individuals about the choices and means, if any, we offer individuals for limiting the use or disclosure of their information.

Disclosures and Transfers

We have the individual's permission to make the disclosure;
The disclosure is required by law or professional standards;
The disclosure is reasonably related to the sale or disposition of all or part of our business;
The information in question is publicly available;
The disclosure is reasonably necessary for the establishment or defense of legal claims; or
The disclosure is to another TERIS 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; or
subscribes to the Principles.

Permitted transfers of information, either to third parties or within TERIS, 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

To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of our clients, TERIS has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we process. However, we cannot guarantee the security of information on or transmitted via the Internet or Review tool.

Data Integrity

TERIS processes personal information only in ways compatible with the purpose for which it was collected or subsequently 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.

Access and Correction

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. We will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate. The individual will need to provide sufficient identifying information, such as name, address, birth date, and social security number. 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

Enforcement and Dispute Resolution

TERIS utilizes the self-assessment approach to assure its compliance with our privacy statement. TERIS periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles. We encourage interested persons to raise any concerns with us using the contact information below. We 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.

With respect to any complaints relating to this policy that cannot be resolved through our internal processes, we have agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities to resolve disputes pursuant to the Safe Harbor Principles. In the event that we or such authorities determine that we did not comply with this policy, we will take appropriate steps to address any adverse effects and to promote future compliance.

Any person who we determine is in violation of our privacy policies will be subject to disciplinary process.

CONTACT INFORMATION

Questions or comments regarding our Safe Harbor certification should be submitted to TERIS by mail or e-mail as follows:

TERIS
Office of the General Counsel
1001 Fourth Avenue
Suite 2110
Seattle, WA 98154
USA
safeharbor@teris.com

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