Privacy Statement for Visitors to ClickFox Web Sites
At ClickFox your privacy is of utmost importance. ClickFox is committed to preserving your trust and confidence. That is why we want you to understand how we handle information we learn about you from your visit to this web site, what measures we take to safeguard that information and our commitment to data security. In order to maintain your privacy, ClickFox adheres to the following privacy principles:
Collection and Use of Visitor Information
We use our own product, ClickFox, to analyze traffic to our web sites. This information is used in aggregate to analyze and improve our web sites.
A cookie cannot read personal data off your hard disk or read cookie files created by other sites; indeed, the only Personal Information a cookie can contain is information you supply yourself. Accepting the cookies used on our website may give us access to information about your browsing behavior, which we may use to personalize your experience and track user traffic patterns, and to merge this info when you register. We do this in order to determine the usefulness of our website information to our users and to see how effective our navigational structure is in helping users reach that information. You may browse most of ClickFox’s website without accepting cookies from ClickFox; however, some website functionality may be lost by disabling cookies on your computer. Other ClickFox web pages, particularly those which require a login and password, require cookies and cannot be used when you have disabled cookies in your browser.,
If you prefer not to receive cookies while browsing our website you can set your browser to warn you before it accepts cookies or refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser. For additional information about cookies and other tracking technologies, including instructions for blocking their use, see http://privacy.getnetwise.org/browsing/tools.
Privacy Statement for Visitors to Sites that Use ClickFox
At ClickFox the privacy of visitors to our customer’s web sites is of utmost importance. In order to maintain your privacy, ClickFox adheres to the following privacy principles:
No Collection of Personal Information
Collection of Non–Personally Identifiable Information
ClickFox collects anonymous visitor information like IP addresses, browser types (such as Microsoft Internet Explorer or Netscape Navigator), referring pages, pages visited and time spent on the web site. ClickFox collects this non–personally identifiable information for the following purposes:
- To provide anonymous statistical analysis of web page traffic patterns to our customers for their web sites
- To administer our web site and servers
- To allow for auditing of our services by third parties
- To improve our services
Use of Anonymous IP Address
IP addresses are recorded by every site on the internet. ClickFox, Inc. collects this information as well, but does so exclusively anonymous statistical purposes.
No Individual Profiling
ClickFox does not create individual profiles of visitors. Unlike other tracking services we do not have a database of individual profiles of each visitor.
Third Party Access
Our customers control access to ClickFox web traffic analysis reports. ClickFox does not provide access to anyone other than the users identified by our customers. ClickFox anonymous traffic data for a customer’s web site may be provided to an auditing service upon request from such customer.
Privacy Statement for Customers Using ClickFox to Analyze Web Traffic
At ClickFox the privacy and security of our customer’s information is of utmost importance. In order to maintain your privacy, ClickFox adheres to the following privacy principles:
Your Information is Secure
All the traffic information we compile for your web site and personal information that we collect about you and your visitors is considered confidential. Access to this information is protected by usernames and passwords. You should keep your password and user name confidential.We have implemented industry standard security mechanisms to protect this information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Examples include password protected access and firewalls.ClickFox software and hardware are configured to provide effective security.
ClickFox Has Limited Access to your Information
ClickFox will not access, modify, or otherwise divulge the traffic information we compile for your site except for the express purpose of generating reports which have been authorized by you or otherwise agreed to by you, or unless acting under a good faith belief that such action is necessary to:
- Conform to legal requirements or comply with legal process
- Protect and defend the rights or property of ClickFox
- Enforce our agreements with customers and visitors
- Troubleshoot any service problems
Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “Directive”) permits transfers of Personal Data from an EU member state to a non-EU member state only if such non-EU member state provides an “adequate level of protection.” The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions regarding the transfer of Personal Data from the EU to the United States (the “Safe Harbor Principles”) that satisfy the “adequate level of protection” requirement of the Directive. ClickFox, consistent with its commitment to protect personal information, adheres to principles consistent with the Safe Harbor Principles.
For purposes of this Policy, the term “Personal Data” means any information relating to a natural person within the member states of the EU who is identified or who can be identified directly or indirectly in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.
Personal Data that is transferred to ClickFox in the US from the EU falls under one of the following situations:
- EU Company provides Personal Data – ClickFox provides customized data index, search and access services to EU companies. In this capacity, ClickFox does not own or control any of the Personal Data it processes on behalf of a ClickFox’s customer. All such Personal Data is owned and controlled by such ClickFox’s customer.
- ClickFox receives Personal Data transferred from the EU to the US merely as a processor on behalf of its customers through a secured medium – SFTP, IPSec, etc. ClickFox will not disclose or share this information with anyone and will strictly comply with its policy statement.
- ClickFox collects Personal Data on the employees of ClickFox affiliates in the EU states. This information is used for employment related decisions, including who to hire, retain, promote or re-assign. It may also be provided to ClickFox agents who will use this information to conduct background checks and credentials verification. It may also be used to conduct employee investigations where ClickFox has a suspicion of work related misconduct or wrongdoing, or an issue arises as to employee compliance with applicable laws and/or regulations or any ClickFox policies. Human resources and security professionals will utilize the Personal Data. ClickFox will strictly adhere to its policy and procedure policy while collecting the Personal Data. ClickFox internal assessment team will monitor the adherence on a regular basis.
The privacy principles in this Policy are based on the Safe Harbor Principles.
- NOTICE: Where ClickFox collects Personal Data directly from individuals in the EU, it will inform them about the purposes for which it collects and uses Personal Data about them, the types of non-agent third parties to which ClickFox discloses that information, and the choices and means, if any, ClickFox 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 Data to ClickFox, or as soon as practicable thereafter, and in any event before ClickFox uses the information for a purpose other than that for which it was originally collected.
- Where ClickFox receives Personal Data from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
- ClickFox is not responsible for the content of the Personal Data it collects, which may include personally identifying information, nor is ClickFox responsible for the way its customers treat personally identifying information included in reports.
- CHOICE: Where ClickFox collects Personal Data directly from individuals in the EU countries, ClickFox 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, ClickFox 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. ClickFox will provide individuals with reasonable mechanisms to exercise their choices.
- ONWARD TRANSFERS TO AGENTS: ClickFox will obtain assurances from its agents that they will safeguard personal information consistent with this Policy. 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), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding. Where ClickFox has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, ClickFox will take reasonable steps to prevent or stop the use or disclosure.
- SECURITY: ClickFox will employ reasonable safeguards to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. For personal information subject to electronic storage or transmission, ClickFox maintains an internal private, secure global network that is protected from computer virus infection and monitored for unauthorized access. Both electronic and paper based records holding personal information are maintained in access controlled facilities.
- DATA INTEGRITY: ClickFox will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. ClickFox will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
- ACCESS: Upon request, ClickFox will grant individuals reasonable access to personal information that it holds about them. In addition, ClickFox will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
- ENFORCEMENT: ClickFox will conduct an annual self-assessment to ensure that this Statement is published and disseminated within ClickFox and on its website and that it conforms to the Principles. In addition, ClickFox has deployed internal processes to monitor ClickFox’s compliance with the Principles and to address all questions or complaints. ClickFox will also self-certify annually with the U.S. Department of Commerce as being in compliance with the Principles.
- Individuals may raise any concerns or complaints regarding their personal data directly with ClickFox by contacting the ClickFox Privacy Officer, whose contact information is as follows: privacy@ClickFox.com.
- If an individual raises such a concern or complaint, ClickFox will investigate the matter and attempt to resolve all issues to the satisfaction of the individual raising the concern or complaint. If the matter cannot be settled at that stage, ClickFox agrees to cooperate with competent EU Data Protection Authorities (DPAs).
- MODIFICATION AND AMENDMENT: ClickFox may modify or amend this Statement from time to time by posting a revised Statement on the web at www.ClickFox.com. If ClickFox amends this Statement, the new statement will apply to personal data previously collected only insofar as the rights of the individuals affected are not reduced. So long as ClickFox adheres to the Safe Harbor Agreement, ClickFox will not amend this Statement in a manner inconsistent with the Principles.
To learn more about the Safe Harbor program, and to view ClickFox’s certification, please visit http://www.export.gov/safeharbor/.
ClickFox may update this policy from time to time to describe how new site features affect ClickFox’s use of your information and to let you know of new control and preference features that we provide you. Updates will be posted on our Web site.
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