The United State Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (FAQ) (the “U.S.-EU Safe Harbor Framework”) to enable U.S. companies to satisfy European Union (EU) law requirements for adequate protection of personal information transferred from the European Economic Area (“EEA”) to the United States. The United State Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of data protection principles and frequently asked questions (FAQ) (the “U.S.-Swiss Safe Harbor Framework”) to enable U.S. companies to satisfy Swiss law requirements for adequate protection of personal information transferred from Switzerland to the United States. PITC adheres to the Safe Harbor Principles outlined below.

PRIVACY PRINCIPLES:

The privacy principles in this policy are based on the Safe Harbor Principles.

INFORMATION COLLECTION & USAGE:


Through this Safe Harbor Privacy Policy, Partners In Trade Compliance, herein noted as “PITC” notifies individuals about the purposes for which it collects their personal information, and the types of third parties to which it may disclose their personal information.

PITC uses several methods for collecting information. We do not sell, share or rent this information to others outside of the PITC company, its accounting firm or partners. Any information collected by PITC will remain confidential and be used for business purposes only.  This includes such things as financial and contact information that is used to provide accurate contracts, billing and communication. PITC tracks and catalogs certain information regarding clients within our accounting software, and performs the necessary trade compliance screening of it’s clients and potential clients.

DISCLOSURE AND TRANSFER:

PITC will not sell, trade, or disclose to third parties any individually (either client or PITC employee) personal information, derived from the use of any PITC service, (except as required by subpoena, search warrant or other legal process or in the case of imminent physical harm to the customer or others). When PITC uses other agents, contractors or companies to perform services on its behalf, PITC will ensure that the company protects personal information consistent with this policy. 

PITC will obtain reasonable assurances from its agents that they will safeguard personal information collected by PITC consistently with this Policy and the Safe Harbor Principles. Examples of appropriate assurances may include: nondisclosure agreements, a contract obliging the agent to afford a level of protection to the personal information that is at least equivalent to the Safe Harbor Principles; Safe Harbor certification by the agent; or the agent being subject to EU Directive 95/46/EC or other law providing an adequate level of privacy protection.

This provision does not apply to public record information or publicly available information except in certain situations as defined by the Safe Harbor Program.

SECURITY:

PITC conducts personnel training, technology and strict policy guidelines to safeguard the privacy of personal information from distribution, unauthorized access or improper use. However, we cannot guarantee the security of personal information.

DATA INTEGRITY:

PITC will take reasonable measures to ensure that personal information is relevant for its intended use, reliable for its intended use, accurate, complete, and current.

IMPROPER CONDUCT:

PITC may use personal information to investigate and help prevent potentially unlawful activity or activity that otherwise violates the customer agreement for stated service.

ACCOUNT INFORMATION UPDATE AND ACCESS:

PITC honors reasonable requests from clients for changes in account information, and will correct any such information that is inaccurate. Personal information may be updated/removed through an email request  (web@pitc2011.com ). PITC may limit or deny access to personal information, or charge a fee, where providing such access would be unreasonably burdensome or expensive under the circumstances or as otherwise permitted by the Safe Harbor Principles.

NOTICE:

PITC informs individuals in the EU about the purposes for which it collects and uses their personal information, and how to contact PITC, the types of third parties with which PITC shares their personal information in relation to it’s typical business process, and the method PITC offers for limiting the use and disclosure of their personal information.

Consistent with the Safe Harbor requirements, PITC may not be in a position to furnish notice in certain limited situations. Specifically, notice is not required where the processing of EU personal information is necessary to respond to a government inquiry; is required by applicable laws, court orders or government regulations; or is necessary to protect PITC legal interests and providing notice would interfere with those interests.

ENFORCEMENT:

PITC utilizes the self-assessment approach to assure its compliance with our Safe Harbor Privacy statement. PITC periodically verifies that the policy is current and accurate, comprehensive for the information intended to be covered, openly displayed, implemented and in conformity with the Safe Harbor Principles.

Any questions, concerns, or complaints concerning the collection and use of personal information by PITC should be directed to the email address of web@pitc2011.com or alternatively calling (941) 468-1384. PITC will conduct a reasonable review of said request and will attempt to resolve any complaints in accordance with the principles contained in this Policy. For complaints that cannot be resolved between PITC and the complainant, PITC agrees to participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles.

LIMITATION ON SCOPE OF PRINCIPLES:

Adherence to this Privacy Policy may be limited to the extent required to meet a legal, governmental, national security or public interest obligation.

SAFE HARBOR STATEMENT