iNET Interactive recognizes that the EU has an “omnibus” data protection regime established pursuant to the European Data Protection Directive (95/46/EC) (the “Directive”) and that Switzerland has a comprehensive data protection law (together, the “Data Protection Laws”). Consistent with its pledge to protect personal privacy, iNET Interactive adheres to the Data Protection Laws.
This Policy applies to all personal information received by iNET Interactive in the United States from the EU and Switzerland, in any format including electronic, paper or verbal.
The following definitions shall apply throughout this Policy:
“Agent” means any third party that uses personal information provided to iNET Interactive to perform tasks on behalf of and under the instructions of iNET Interactive.
“iNET Interactive” means iNET Interactive, its successors, subsidiaries, divisions and groups in the United States.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of iNET Interactive to identify an individual. Personal information does not include information that is encoded, anonymized, or aggregated, nor does it include publicly available information 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, or trade union membership, or that concerns health or sex life. In addition, iNET Interactive will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Policy are based on the Data Protection Laws.
NOTICE: When iNET Interactive collects personal information directly from individuals in the EU and Switzerland, it will inform them about the purposes for which it collects and uses their personal information, the types of non-agent third parties, if any, to which iNET Interactive discloses that information, and the choices and means, if any, that iNET Interactive 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 iNET Interactive, or as soon as practicable thereafter, and in any event before iNET Interactive uses the information for a purpose other than that for which it was originally collected.
If iNET Interactive receives personal information from its subsidiaries, affiliates or other entities in the EU and Switzerland, it will use such information in accordance with the notices such entities provided and the choices made by the individuals to whom such personal information relates.
CHOICE: iNET Interactive 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, iNET Interactive 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.
iNET Interactive will provide individuals with reasonable methods to exercise their choices.
DATA INTEGRITY: iNET Interactive will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. iNET Interactive will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: iNET Interactive will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. If iNET Interactive has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, iNET Interactive will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, iNET Interactive will grant individuals reasonable access to personal information that it holds about them, and iNET Interactive will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: iNET Interactive will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT: iNET Interactive will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that iNET Interactive determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the iNET Interactive Privacy Office at the address given below. iNET Interactive 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 iNET Interactive and the complainant, iNET Interactive has agreed to participate in the dispute resolution procedures of the Data Protection Laws.
Questions or comments regarding this Policy should be submitted to iNET Interactive by mail or e-mail as follows:
9100 West Chester Towne Centre Rd
West Chester, OH 45069
This Policy may be amended from time to time, consistent with the requirements of the Data Protection Laws. iNET Interactive will provide appropriate notice of any material changes.
(Adopted July 30, 2012)