Safe Harbor Statement

Net Atlantic respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Not only does Net Atlantic strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding ethical standards in its business practices. This Safe Harbor Policy Statement (the “Safe Harbor Statement”) sets forth the privacy principles Net Atlantic follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.

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 to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the "U.S.-EU Safe Harbor"). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection. The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, Net Atlantic adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”).

SCOPE

This Safe Harbor Statement applies to all personal information received by Net Atlantic in its role as a data processer in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal.

DEFINITIONS

For purposes of this Statement, the following definitions shall apply:

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Net Atlantic or to which Net Atlantic discloses personal information for use on Net Atlantic's behalf.

“Net Atlantic” means Net Atlantic, Inc., its predecessors, 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 Net Atlantic 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 i.e. email address alone or in combination with non-regulated or Sensitive personal information.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Net Atlantic 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 privacy principles in this Statement have been developed based on the Safe Harbor Principles.

NOTICE: Where Net Atlantic 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 Net Atlantic discloses that information, the choices and means, if any, Net Atlantic offers individuals for limiting the use and disclosure of personal information about them, and how to contact Net Atlantic. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Net Atlantic, or as soon as practicable thereafter, and in any event before Net Atlantic uses or discloses the information for a purpose other than that for which it was originally collected.
Where Net Atlantic receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: Net Atlantic 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, Net Atlantic 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.
Net Atlantic will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: Net Atlantic will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Net Atlantic will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: Net Atlantic will obtain assurances from its agents that they will safeguard personal information consistently with this Statement. 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), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Net Atlantic has knowledge that an agent is using or disclosing personal information in a manner contrary to this Statement, Net Atlantic will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, Net Atlantic provides individuals the opportunity to access their personal identifying information on their personal profile that it holds about them. In addition, Net Atlantic permits individuals, i.e. data controllers, who upload personally identifying information, for a fee or on a donation basis, the opportunity to correct, amend, or delete information that they believe to be inaccurate or incomplete.

SECURITY: Net Atlantic will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: Net Atlantic will conduct compliance audits of its relevant privacy practices to verify adherence to this Statement. Any employee that Net Atlantic determines is in violation of this Statement 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 Net Atlantic Compliance Office at the address given below. Net Atlantic will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Statement. For complaints that cannot be resolved between Net Atlantic and the complainant, Net Atlantic has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

  1. for disputes involving all personal information received by Net Atlantic from Switzerland, Net Atlantic has agreed to cooperate with the Swiss FDPIC;
  2. for disputes involving employment-related personal information received by Net Atlantic from the EEA, Net Atlantic has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
  3. Net Atlantic complies with the US-EU Safe Harbor Framework and US-Swiss 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 and Switzerland.  NetAtlantic 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 our certification page, please visit http://www.export.gov/safeharbor/

    In compliance with the US-EU and US-Swiss Safe Harbor Principles, Net Atlantic commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union or Swiss citizens with inquiries or complaints regarding this privacy Statement should first contact Net Atlantic at:


    Chief Compliance Officer
    Net Atlantic, Inc.
    10 Federal Street, Suite 26
    Salem, MA 01970
    legal@netatlantic.com

Net Atlantic has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Net Atlantic, Inc., please visit the BBB EU SAFE HARBOR web site at for more information and to file a complaint.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by Net Atlantic to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

INTERNET PRIVACY

Net Atlantic sees the Internet and the use of other technology as valuable tools to communicate and interact with consumers, employees, healthcare professionals, business partners, and others. Net Atlantic recognizes the importance of maintaining the privacy of information collected online and has created a Privacy Policy governing the treatment of personal information collected through web sites that it operates. With respect to personal information that is transferred from the European Economic Area or Switzerland to the U.S., the Privacy Policy is subordinate to this Statement. However, the Privacy Policy also reflects additional legal requirements and evolving standards with respect to Internet privacy. Net Atlantic's Privacy Policy can be found at www.netatlantic.com.

CONTACT INFORMATION

Questions or comments regarding this Statement should be submitted to the Net Atlantic Privacy Office by mail to:


Chief Compliance Officer
Net Atlantic, Inc.
10 Federal Street, Suite 26
Salem, MA 01970
legal@netatlantic.com

CHANGES TO THIS SAFE HARBOR PRIVACY STATEMENT

This Statement may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on netatlantic.com whenever this Safe Harbor Privacy Statement is changed in a material way.

EFFECTIVE DATE: May 1, 2014