Privacy

Privacy Statement

Safe Harbor Privacy Policy

Safe Harbor: ALTA adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union to the United States of America. ALTA also adheres to the separate Safe Harbor Agreement concerning the transfer of personal data from Switzerland to the United States. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce with respect to all such data. This statement outlines our general policies and practices for implementing the Safe Harbor Principles, including the types of information ALTA gathers and how we use it.

Scope: This Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received by ALTA in any format. ALTA will establish and maintain business procedures that are consistent with this Policy

Privacy Principles

Notice: ALTA treats all material entering the office as confidential. We also work with Confidentiality Agreements with our clients. ALTA maintains private information about its customers on secure systems to aid the company in conducting its business. This information includes contact details and the types of services delivered to each client. We maintain copies in our files of all work that ALTA has done for its customers. ALTA does not rent, sell, loan, or otherwise make this information available to any third party unless required by law or court order.

Our systems are not set up to track, collect or distribute personal information about ALTA website visitors. They do recognize the home server of visitors, but not email addresses. For example, we can tell which Internet Service Provider our visitors use, but not the names, addresses or other information about our visitors that would allow us to identify particular visitors to our sites. This server information is used for internal purposes only by ALTA technical support staff.

In addition, our websites track information about the visits to our web sites. For example, we compile statistics that show the daily number of visitors to our sites, the daily requests we receive for particular files on our web sites and what countries those requests come from. These aggregated statistics are used internally to provide better services to our clients and may also be provided to others, but again, the statistics contain no personal information and cannot be used to gather such information.

Choice: ALTA has found that clients in our industry often require more than one language-related service – for example, testing and translation services. Because of this, we utilize cross-selling to send targeted material to our direct clients who have used our services in the past. We always offer clients the opportunity to opt-out of receiving targeted material. Otherwise, ALTA does not permit the disclosure of personal information to non-agent third parties. ALTA does not market to indirect clients nor use the information about indirect clients for any purpose other than performing services for the direct client.

Data Security: All client communication and files in digital format are stored on a secure network, accessible only by approved staff. All critical systems and servers are separately housed within ALTA’s secure facilities and are accessible only by authorized personnel. Our information security is managed internally and meets industry standards for secure networks. ALTA takes precautions to protect personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. ALTA’s physical premises are protected with a security guard, 24 / 7 / 365, and all off-hour entry is logged through an access control system. ALTA periodically performs network backups. While our backup files are stored offsite, they are handled by authorized personnel only.

Transfer to Agents: ALTA will obtain assurances from our agents that they will safeguard personal information consistent with this Policy. In the event that ALTA has knowledge that an agent is using or disclosing personal information contrary to this Policy, ALTA will take the necessary steps to prevent or stop the use or disclosure.

Access and Correction: An individual may make a request to ALTA for access to the information ALTA maintains about him or her, or the company with which he or she is associated. The individual has the right to receive confirmation from ALTA about the data relating to him/her that ALTA has on file, and to correct, amend, or delete that information when it is inaccurate.

Enforcement and Dispute Resolution: ALTA periodically verifies that the Policy is accurate, comprehensive for the information intended to be covered, and conforms to the U.S.-EU and U.S.-Swiss Safe Harbor Principles. We encourage interested persons to raise any concerns with us using the contact information below. ALTA 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 related to this Policy that cannot be resolved through our internal process, we agree to participate in the dispute resolution procedures of the panel established by EU data protection authorities to resolve disputes that concern the Safe Harbor Principles and to cooperate and comply with the Swiss Federal Data Protection and Information Commissioner. In the event that we or the authorities conclude that we did not comply with the Policy, we will take appropriate steps to address any adverse effects and promote future compliance.

Changes to the Safe Harbor Privacy Policy: This Policy may be amended from time to time, consistent with any changes in the Safe Harbor Principles. Appropriate public notice will be given in the event of such amendments.

Oversight: ALTA’s privacy practices are self-certified as defined in the U.S. Department of Commerce Safe Harbor Program. For more information about the Safe Harbor Program, please go to www.export.gov/safeharbor.

Questions: Questions or comments regarding this Policy should be directed to: Robert Jones, who can be reached by telephone at 404.920.3810, or via email.