International SOS Foundation
Customer Personal Data Privacy Statement
The International SOS Foundation (“ISOSF”) is committed to protecting your privacy and we encourage you to read this privacy statement.
This statement describes:
- the personal data that we collect;
- How we collect data and why
- How data will be used and who we can disclose or transfer data to and why;
- How data can be corrected or deleted;
- The measures that we take to protect data; and
- The process and contact information that customers can use to raise enquiries, concerns and complaints.
1. Commitment to Personal Data Protection
ISOSF is committed to safeguarding your personal data by adherence to the following obligations:
The ISOSF Data Protection Policy, the Information Security Policy and the related policies;
- The United States Government’s Safe Harbor Framework;
- The Binding Corporate Rules sanctioned by the European Community’s data protection authorities; and
- The relevant local data protection laws and regulations.
The Data Protection Policy and the related policies, the United States Safe Harbor Principles can be accessed through the following link,http://www.internationalsos.com/en/files/Policy_DataProtection.pdf. The Binding Corporate Rules will be made available when it has been approved by the data protection authorities in the European Community.
2. What Information is collected and how is it collected?
ISOSF collects personal data about you when you enquire about our activities, register with us, send or receive a communication or otherwise provide us with personal information. We may also receive information about you from third parties, for example from our service providers, that are permitted to share this personal data. You also provide information to us when you choose to email data to us, or you participate in promotional initiatives.
“Personal data” includes information that will allow someone to identify or contact you, including, for example, your full name, address, telephone number (professional & home) or email address, gender, date of birth, nationality, family status (dependent), industry sector information related to professional activity, status (expatriate or traveller) and destinations.
Personal data does not include aggregated data or data that, by itself, does not permit the identification of individual persons, such as statistics.
ISOSF will only gather data that is relevant for the purposes for which it will be used and will not gather excessive or unnecessary data.
ISOSF shall take reasonable steps to ensure that data is reliable, accurate, complete, and current, bearing in mind its intended use. You have a responsibility to keep the data you provide to us updated and we will take reasonable steps to facilitate this.
3. Acceptance and Links to other Websites
This ISOSF website may contain links to other websites, which are provided solely as a convenience to you and not as an endorsement by ISOSF of the contents of other web sites. The other web sites may have their own policies, which ISOSF does not control, and thus are not addressed or controlled by this statement or the ISOSF Data Protection Policy.
ISOSF also uses ‘analytical cookies’. These allow us to recognize and count the number of visitors logging into our web site and to see how visitors move around the site when they are using it. This helps us make sure sites are meeting users’ needs and to find out how we could improve.
The analytical cookies do not capture any personally identifiable information. Most browsers are initially set up to accept cookies. Though most cookies expire after a certain period of time, you can choose to delete a cookie file at any time. You can do so by resetting your browser to refuse all cookies or to indicate when a cookie is sent. However, some ISOSF features or services may not function properly without cookies.
5. How the Personal Data will be used
We will use your personal data:
To, where applicable, provide you with the services, products or information you have requested; for administration purposes; and to further our charitable aims, including for fundraising activities.
As part of this, we may analyse the personal information we collect to create a profile of your interests and preferences so that we can contact you in the most appropriate way and with the most relevant information.
Your personal data may be transferred to companies within the ISOSF group or to service providers that are performing services for ISOSF or acting as ISOSF’s agents. ISOSF will require that any such service providers agree to keep your personal data secure and confidential, use it only for the purposes for which the personal data is transferred and use it only in accordance with ISOSF’s directions.
Your personal data may be transferred to Government authorities, agencies and institutions as required or permitted by applicable laws and regulations. ISOSF shall not collect, use, disclose or transfer your personal data except as described in this Statement unless you give us your permission to collect, use, disclose or transfer it for other purposes.
Consent: By providing personal data to ISOSF you consent to the processing of such data by ISOSF as described in this Privacy Statement. You can alter your preferences as described in Clause 7 below.
6. Data Protection for Children
ISOSF does not knowingly collect any information on persons who have not attained the age of 18 years through the online services and the ISOSF website.
7. Accessing Personal Data
You have the right to ask ISOSF, in writing, for a copy of all the personal data held about you. Processing such a request may be contingent on the payment of an administration fee, your will be advised if such a fee is applicable upon receipt of your request. If you would like to access your personal data held by ISOSF, please apply in writing to firstname.lastname@example.org.
8. Correcting Inaccuracies in Personal Data
In order to update, delete, amend or block any personal information that we create and that we are able to change, contact us using the following e-mail address: email@example.com. Should you need our assistance to access or make changes to your personal information, please submit your request to us. Corrections or deletions of data resulting solely from errors by ISOSF or our service providers shall be paid for by ISOSF.
If you do not wish to contact ISOSF via the abovementioned email address, you may contact our Data Protection Administrators who are also our Country General Managers, responsible for the country in which you are residing or receiving products or services. The contact details of the Data Protection Administrators are attached to this statement.
In making your request to review, update, amend or block data, you will be required to provide ISOSF with details of the data requested and the reasons why the data needs correction. ISOSF will ask for proof of your identity. ISOSF may ask you to assist in verifying the accuracy of the updates and the amendments to the personal data.
ISOSF may ask you to cover the reasonable cost of accessing and providing copies of your personal data if this is not provided through the ISOSF website.
ISOSF will strive to address your request as soon as practicable and no later than thirty (30) calendar days from the date your request is received and understood.
If ISOSF is asked to destroy the personal data, ISOSF shall use means that prevents its recreation and ISOSF shall take reasonable care to ensure that there is no unauthorised disclosure during the destruction of the data.
9. What Kind of Security Procedures are Used to Protect the Loss, Misuse, or Alteration of Your Personal Data under ISOSF’s Control?
ISOSF takes precautions to protect its users’ information. ISOSF has implemented policies that forbid its employees from using or disclosing personal data in an inappropriate or unlawful manner and maintains security measures to safeguard the personal data that it maintains from unauthorized access, misuse, alteration, loss or destruction.
10. How do I Resolve Disputes with ISOSF Relating to Personal Data?
If you are unsatisfied with the manner in which your question or concern was addressed, in respect of our online services, you may contact ISOSF at firstname.lastname@example.org.
ISOSF Online is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to build users’ trust and confidence in the internet by promoting the use of fair information practices. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at: http://www.truste.org/consumers/watchdog_complaint.php.
TRUSTe will serve as a liaison with Intl.SOS to resolve your concerns.
If you do not wish to make a complaint through our online services, you may direct all enquiries, concerns or complaints regarding the collection, use, storage, correction, deletion, blocking, disclosure or transfer of personal data to the Data Protection Administrator who is also the ISOSF Country General Manager, in the country in which you reside or are receiving services using the contact details attached to this statement.
If you do not receive a satisfactory response from the Data Protection Administrator you may contact the ISOSF Chief Data Protection Officer, who is also the General Counsel of ISOSF using the contact details attached to this statement.
The Chief Data Protection Officer has overall responsibility at ISOSF for protecting personal data.
ISOSF will investigate all concerns and complaints and will address them expeditiously. An acknowledgement of the identity of the employee addressing the complaint and the approximate length of time that will be taken to review the complaint will be provided no later than five (5) business days from the date the complaint is received and understood. Regular updates shall be given to you on the progress of the review if the review is likely to take longer than seven (7) business days.
You have the right at anytime, to raise your issues with a data protection authority or to take your case to a court.
If you receive services from ISOSF through an employer or through a relative’s employer or through an association or institution, or an insurance or financial services program and your personal information has been improperly collected, used, stored, disclosed, amended, destroyed, blocked or transferred as a result of the actions or inactions of the employer, association or institution, insurance company or financial services company, then you will be directed by ISOSF to such employer, association or institution, insurance company or financial services company. ISOSF will not be liable for resolving disputes between you and such companies, associations or institutions.
11. U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework
ISOSF Assistance complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. ISOSF Assistance 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 ISOSF Assistance’s certification, please visit http://www.export.gov/safeharbor/
12. Changes to this Statement
ISOSF reserves the right to change this policy at any time by notifying users through its website of the existence of a new privacy statement. This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights.