TRAUTMANSGUIDE.COM ONLINE AND OFFLINE PRIVACY STATEMENT
Last updated: July 31, 2010.
BY VISITING TRAUTMANSGUIDE.COM, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY STATEMENT.
Protecting the privacy and security of your personal information is a priority at COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™, and we do our best to ensure that your personal information is always handled in a safe and responsible manner in accordance with the following Privacy Principles:
1. What Personal Information Do We Collect?
2. Examples of Information Collected
2. Why Do We Collect This Personal Information?
4. How Does Trautmansguide.com Protect My Privacy?
6. With Whom Do We Share Your Personal Information?
7. How Secure Is Information About Me?
8. What About Third-Party Advertisers and Links to Other Websites?
9. Which Information Can I Access?
10. What Choices Do I Have?
11. Are Children Allowed to Use Trautmansguide.com?
12. Trautmansguide.com Does Not Knowingly Collect Personal Information from Children
13. Does Trautmansguide.com Participate in the Safe Harbor Program?
14. Conditions of Use, Notices, and Revisions
14. Examples of Information Collected
1. WHAT PERSONAL INFORMATION DO WE COLLECT?
Personal information is information that can be used to identify, contact or locate you. For example, personal information can include your name, e-mail address, billing address, shipping address, phone number, or credit card information. The information compiled by COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ incorporates several data elements for businesses and individual customers. The information is acquired from reliable sources and COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ takes great care through specific quality control procedures to verify and maintain the accuracy of the information. COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ does not collect personally identifiable information about visitors except when visitors specifically provide such information on a voluntary basis. For example, such personally identifiable information may be gathered from the registration process for subscription sites or services and in connection with content submissions, community postings (e.g., chat and bulletin boards), suggestions, and transactional areas. Such information may be used by COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ for the following purposes: contacting a subscriber regarding account status, changes to the subscriber agreement, special discounts, promotions, products offered and other matters relevant to the underlying service and/or the information collected.
COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ values opinions and comments from visitors, so we occasionally conduct online surveys. These surveys are entirely optional for all visitors. Most frequently, the information is aggregated and used to make improvements to COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ web sites and to develop appealing content, features and promotions for visitors. Survey participants are anonymous unless otherwise stated in the survey. COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ reserves the right to perform statistical analyses of visitor’s behavior and characteristics. In order to measure interest in and use of the various areas of the site and to inform advertisers of such information as well as the number of visitors that have been exposed to or clicked on their advertising banners. COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ will provide only aggregated data from these analyses to third parties. Also, visitors should be aware that COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ may sometimes permit third parties to offer subscription and/or registration-based services through a COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ web site.
2. EXAMPLES OF INFORMATION COLLECTED
INFORMATION YOU GIVE US
You provide most such information when you register to be included in one of our publications, search, buy, post, participate in a contest or questionnaire, or communicate with our customer service. For example, you provide information when you search for a product; place an order through Trautmansguide.com or one of our third-party sellers; provide information in Your Account (and you might have more than one if you have used more than one e-mail address when shopping with us) or Your Profile; communicate with us by phone, e-mail, or otherwise; complete a questionnaire or a contest entry form; provide employer information when opening a corporate account; participate in Discussion Boards or other community features; share information with members of a relevant community; and employ other Personal Notification Services. As a result of those actions, you might supply us with such information as your name, address, and phone numbers; credit card information; people to whom purchases have been shipped, including addresses and phone number; e-mail addresses of purchasers and other people; content of reviews and e-mails sent to us; personal description and photograph in your personal profile; and financial information, including Social Security and driver’s license numbers. You may also submit information to us about yourself for inclusion in one or more of our guides / directories (a “Biographical Submission”). Our use of “Biographical Submissions” is not governed by this Privacy Statement. Please see our Legal Information and Notices instead.
INFORMATION FROM OTHER SOURCES
Examples of information we receive from other sources include updated delivery and address information from our carriers or other third parties, which we use to correct our records and deliver your next purchase or communication more easily; account information, purchase or redemption information, and page-view information from some merchants with which we operate co-branded businesses or for which we provide technical, fulfillment, advertising, or other services; search term and search result information from some searches conducted through the Web search features offered by our subsidiaries; search results and links, including paid listings (such as Sponsored Links); and credit history information from credit bureaus, which we use to help prevent and detect fraud and to offer certain credit or financial services to some customers.
CO-BRANDED AND JOINT OFFERINGS
We may choose to work with other businesses to offer joint or co-branded products and other offerings.
INFORMATION YOU CAN ACCESS
Examples of information you can access easily at Trautmansguide.com include up-to-date information regarding recent orders; personally identifiable information (including name, e-mail, password, communications and personalized advertising preferences, address book, and other settings); payment settings (including credit card information and gift certificate, gift card, and check balances); e-mail notification settings (including alerts, notifications of product and other special promotions, newsletters); recommendations (including recent product view history and prior order history).
3. WHY DO WE COLLECT THIS PERSONAL INFORMATION?
We collect your personal information in an effort to provide you with a superior customer experience and, as necessary, to administer our business. It allows us to provide you with easy access to our products and services, with a particular focus on the items and programs that may be of most interest to you. For more information as to why we collect personal information, please see the section below entitled: “How do we use your personal information?”
Your personal information also allows us to communicate with you about special offers, promotions, and other marketing programs and news that may be of interest to you.
4. HOW DOES TRAUTMANSGUIDE.COM PROTECT MY PRIVACY?
We at Trautmansguide.com are keenly aware of the trust our users place in us and our responsibility to protect their privacy. We believe the foundations of privacy are rooted in transparency and choice. To assist you in reaching informed decisions about your own privacy, we want to inform you of the information we collect when you use our services and products and how we utilize that information to improve your service. We also attempt to give you meaningful choices when possible about the information you provide to Trautmansguide.com and others. The information we learn from customers helps us personalize and continually improve your corporate governance, business intelligence and community experience at Trautmansguide.com. Here are the types of information we gather.
Information From Public Sources: We may receive and store information that is available from sources in the public domain. We use this information to augment and compile data we publish in our products.
Information You Give Us: We receive and store any information you enter on our Web site or give us in any other way. You can choose not to provide certain information, but then you might not be able to take advantage of many of our features. We use the information that you provide for such purposes as responding to your requests to be listed in any of our products, customizing future benefits for you, improving our products, and communicating with you.
Information Collected Using Pixel Tags or Clear GIFs: To help us understand the effectiveness of certain of our communications and marketing efforts, we may use “message format” and “message open” sensing technologies that use pixel tags or clear GIFs (which are also called web beacons). These technologies allow us to know if your e-mail program is able to accept HTML e-mails and, if it is, to: (1) send you e-mails in that format; and (2) determine if you have opened our e-mail messages.
Information Collected from Outside Sources: We may periodically collect personal information and other information about you from other sources such as business partners, contractors and/or other third parties.
Information Collected from Visitors from Outside the United States: If you are visiting Trautmansguide.com from outside the United States and provide us with personal information, please note that your personal information will be transferred, stored and processed within the United States. The data protection laws in the United States may not be as comprehensive as those in your country.
By doing business or interacting with Trautmansguide.com, you are consenting to the transfer of your personal information to facilities located in the United States and other facility locations selected by Cogent Information Analytics, Inc., dba Trautman’s Guide™, present and future successors, assigns, parents or subsidiaries.
E-mail Communications: To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from Trautmansguide.com if your computer supports such capabilities. We may also compare our user list to lists received from other companies, in an effort to avoid sending unnecessary messages to our users. If you do not want to receive e-mail or other mail from us, please adjust your Customer Communication Preferences.
Cookies Defined: A cookie is a small file containing alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and to provide features such as automated purchasing, personalized advertisements on other Web sites (e.g., any site having content served by Trautmansguide.com and Web sites using our affiliated payment service), and storage of items in your Shopping Cart between visits.
Site Analytics: We work with a third party service provider to help us better understand how you use our Trautmansguide.com websites. This third party service provider will place cookies on your computer to collect information. The information this third party service provider collects will tell us things like which search engine referred you to our websites, how you navigated around our websites, what you purchased and what traffic is driven by banner ads and emails. This information will help us to better serve you and provide you with more personalized information and product offerings. We do not allow this third party service provider to collect your credit card information, e-mail address or password information. This third party service provider may only use your personal information to perform services for us. This third party service provider is contractually required to maintain all of the information it collects and analyzes for us securely and in confidence. This third party service provider may not share your personal information with anyone else, or use it for any other purpose, except on an aggregate, non-personal basis.
Please note that this third party service provider collects data on our Trautmansguide.com websites using first-party data collection. As a result, blocking cookies from third-party domains will not block these first-party cookies. As a visitor to Trautmansguide.com, you may choose to opt-out of this third party’s analysis of your browsing and purchasing behavior on our websites. To opt-out on Trautmansguide.com please click here.
6. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Information about our customers and information regarding relevant communities is an important part of our business. We share customer information only as described below and with subsidiaries or affiliates of Cogent Information Analytics, Inc., dba Trautman’s Guide™, present and future successors, assigns, parents or subsidiaries. COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ complies with all applicable federal and state laws concerning data privacy, as well as best practices and procedures and guidelines established by industry groups of which the company may be a member. COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ maintains agreements with its customers containing strict controls on the data as required by the applicable laws and industry standards.
Affiliated Businesses We Do Not Control, Such As Service Providers: We work closely with affiliated businesses. In some cases these businesses operate stores at Trautmansguide.com or sell offerings to you at Trautmansguide.com. In other cases of co-branded and joint offerings, we operate stores, provide services, or sell product lines jointly with these businesses. You can tell when a third party is involved in your transactions, and we share customer information related to those transactions with that third party. We may share Personally Identifiable Information with third parties, who may contact you to offer products and services. At any time, you can contact trautmansguide.com by sending an e-mail to email@example.com to request that we not share your personal information with third parties.
Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf. These are third party providers of products and services you may purchase from or through us (i.e. corporate governance materials). These third parties do not have the right to use personal information we provide to them in any way that is not authorized by COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™. They are contractually obligated to use such information only as necessary to assist us and to maintain the confidentiality and security of such information.Examples include fulfilling orders, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing and product production assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes.
Third Party Membership Programs: We may work with certain third party entities to help them administer their own membership or rewards programs by providing them with purchasing information about their customers who make purchase from COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™. We disclose only the information that is necessary to make these third party programs work and to support your membership in them. This information usually includes your name and e-mail address as well as the dollar amount of the purchases made at COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™. We require such entities to obtain your consent before we provide them with this information, which they usually do as part of their own membership or participation rules.
Credit Card Companies: Credit card transactions are handled by third party financial institutions and their vendors and contractors who receive credit card numbers and other personal information from us to verify the credit card numbers and process transactions.
Law enforcement officials and as required by law: COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ may release personal information to third parties when we determine, in our judgment, that it is necessary to (a) comply with the law, regulation, legal process, or enforceable governmental request; (b) enforce or apply the terms of any of our policies or user agreements; or (c) protect the rights, property or safety of COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™, its successors, assigns, parents, subsidiaries and affiliates, including Trautman’s Guide™ sites around the world (collectively, the “Site”)., our employees, our customers, users, or others.
Promotional Offers: Sometimes we send offers to selected groups of Trautmansguide.com customers on behalf of other businesses. When we do this, we do not give that business your name and address. If you do not want to receive such offers, please adjust your Customer Communication Preferences.
Business Transfers: As we continue to develop our business, we might sell or buy products, websites, stores, subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the customer consents otherwise). Also, in the unlikely event that Trautmansguide.com, Inc., or substantially all of its assets are acquired, customer information will of course be one of the transferred assets.
Protection of Trautmansguide.com and Others: We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Conditions of Use and other agreements; or protect the rights, property, or safety of Trautmansguide.com, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. Obviously, however, this does not include selling, renting, sharing, or otherwise disclosing personally identifiable information from customers for commercial purposes in violation of the commitments set forth in this Privacy Notice.
Purchase of Certain Publications and Subscriptions: Please be aware that in connection with some magazine or newspaper subscriptions and single issue purchases of magazines or newspapers placed on Trautmansguide.com or another of our affiliated sites, in order to complete your transaction, we may need to forward your name, magazine or newspaper order, email address, and shipping or billing address to our content providers. The content providers will share your magazine or newspaper order information as well as your name and address, or name and e-mail and shipping or billing addresses with the magazine or newspaper publisher and magazine or newspaper circulation auditors. Magazine and newspaper publishers may use this information to fulfill your order and for other purposes. Your credit card information will not be shared with them.
With Your Consent: Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information.
7. HOW SECURE IS INFORMATION ABOUT ME?
COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ uses several security systems and procedures to safeguard the information, ensuring the data is accessed only by authorized individuals for legitimate business needs. COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ will not transmit or sell the compiled information to third parties without obtaining a written or electronic agreement that defines the rights and responsibilities with respect to the data. Further, COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ will review our customer’s use of the data to ensure sensitive data is being handled in accordance with required protections, and that this information is not used for deceptive, misleading, distasteful, or suspicious purposes. COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ is responsible for the security of personal information provided by visitors. Strict measures will be taken to assure against unauthorized access, alteration, or dissemination of personal information. COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ is responsible for the security of personal information provided by visitors. Strict measures will be taken to assure against unauthorized access, alteration, or dissemination of personal information.
(A). We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
(B). We reveal only the last four digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
(C). It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer. Click here for more information on how to sign off.
8. WHAT ABOUT THIRD-PARTY ADVERTISERS AND LINKS TO OTHER WEBSITES?
Our site(s) may include third-party advertising and links to other Web sites. We do not provide any personally identifiable customer information to these advertisers or third-party Web sites. Click here for more information about our Advertising Policies and Specifications.
Trautmansguide.com also displays personalized third-party advertising based on personal information about customers, such as purchases on Trautmansguide.com, visits to affiliated Web sites, or use of affiliated payment services on other Web sites. Click here for more information about the personal information that we gather. Although Trautmansguide.com does not provide any personal information to advertisers, advertisers (including ad-serving companies) may assume that users who interact with or click on a personalized advertisement meet their criteria to personalize the ad (for example, users in the Southern United States who bought one of our corporate governance products). If you do not want us to use personal information that we gather to allow third parties to personalize advertisements we display to you, please adjust your Advertising Preferences.
9. WHICH INFORMATION CAN I ACCESS?
Trautmansguide.com gives you access to a broad range of information about your account and your interactions with Trautmansguide.com for the limited purpose of viewing and, in certain cases, updating that information. Click here to see some examples, the list of which will change as our Web site evolves.
10. WHAT CHOICES DO I HAVE?
Upon a reasonable request, COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ will explain to businesses and consumers the nature and types of sources used to compile the data. COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ maintains procedures by which businesses can request corrections for any incorrect data, as well as request any business or consumer information be suppressed from compiled lists which are marketed to COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ customers. Requests for information or access can be made in writing to COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™, Attn: Content Feedback, P.O. Box 796216, Dallas, TX 75379 or firstname.lastname@example.org.
Opt Out Policy
Upon a visitor’s written request, COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ will:
- allow any visitor to “opt out” of further promotional contacts;
- use reasonable efforts to allow visitors to update/correct personal information previously submitted which he/she states is erroneous to the extent such activities will not compromise privacy or security interests; and
- initiate reasonable efforts to functionally delete the visitor and his/her personal information from its database. Visitors should be aware that it might be impossible to completely delete erroneous information or a visitor’s personal information without some residual information remaining in its database because of backups and records of deletions.
(A). As we have discussed above, you can always choose not to provide information, even though it might be needed to make a purchase or to take advantage of such Trautmansguide.com features as our free directory listings or the Director’s Marketplace™.
(B). You can add or update certain information on pages such as those referenced in the “Which Information Can I Access?” section. When you update information, we usually keep a copy of the prior version for our records.
(C). If you do not want to receive e-mail or other mail from us, please adjust your Customer Communication Preferences. (If you do not want to receive Conditions of Use and other legal notices from us, such as this Privacy Notice, those notices will still govern your use of Trautmansguide.com, and it is your responsibility to review them for changes.)
(D). If you do not want us to use personal information that we gather to allow third parties to personalize advertisements we display to you, please adjust your Advertising Preferences.
11. ARE CHILDREN ALLOWED TO USE TRAUTMANSGUIDE.COM?
Trautmansguide.com does not sell products for purchase by children.
12. TRAUTMANSGUIDE.COM DOES NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM CHILDREN
Our products and services are marketed for and directed towards purchase by adults or with the consent of adults. Individuals under the age of 18 (“Minors”) are not permitted to use Trautmansguide.com websites without the supervision of a parent or legal guardian. Furthermore, we do not knowingly collect or solicit personal information from children under the age of 13 or knowingly allow such persons to register for an online account or to post personal information on our websites. Should we learn that someone under the age of 13 has provided any personal information to or on any of the Trautmansguide.com websites, we will remove that information as soon as possible.
13. DOES TRAUTMANSGUIDE.COM PARTICIPATE IN THE SAFE HARBOR PROGRAM?
Introduction and Policy Statement
The EU adopted the Directive on Data Protection (“EU Directive”), which requires EU member states to adopt laws protecting Personal Data collected within their borders. These laws must, among other provisions, restrict the transfer of Personal Data only to countries that have data protection laws deemed “adequate” under standards established in the EU Directive. The U.S. Department of Commerce and the European Commission have agreed on the Principles to enable U.S. Companies to satisfy the requirement under EU law that adequate protection be given to Personal Data transferred from the EU to the U.S.
“Cogent” – means COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™, a Texas corporation, and its domestic and foreign subsidiaries, divisions, groups, and affiliates.
“Identifiable Person” – means a natural person that is or can be identified, directly or indirectly, as a particular person by reference to an identification number or to one or more aspects of the person’s physical, physiological, mental, economic, cultural or social identity. Identifiable Persons may include any employee, applicant, former employee, or retiree of Cogent, its operating divisions, or subsidiaries in the EU.
“Personal Data” – is any information about an Identifiable Person that
- is within the scope of the EU Directive;
- is received by Cogent in the U.S. from the EU;
- is recorded in any form;
- is about, or pertains to, a specific individual; and
- can be linked to that individual.
Personal Data does not include information that is encoded, anonymized, or publicly available information that has not been combined with non-public Personal Data.
“Processing” – means any online, offline or manual processing and includes such activities as copying, filing, and inputting Personal Data into a database.
“Sensitive Data” – is data that pertains to medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation or any other data that is identified as “sensitive” by the Identifiable Person.
Where Cogent collects Personal Data directly from Identifiable Persons in the EU, it will inform them about the type of Personal Data collected, the purposes for which it collects and uses the Personal Data, the types of non-agent third parties to which Cogent discloses or may disclose that information, and the choices and means, if any, Cogent offers individuals for limiting the use and disclosure of their Personal Data. Notice will be provided in a clear and conspicuous language when individuals are first asked to provide Personal Data to Cogent, or as soon as practicable thereafter, and in any event before Cogent uses or discloses the information for a purpose other than that for which it was originally collected. Where Cogent receives Personal Data from their subsidiaries or operating divisions in the EU, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to which the Personal Data relates.
To the extent practical and appropriate, Cogent collects Personal Data directly from the Identifiable Person. In those cases where Cogent collects Personal Data from other persons, it takes measures to respect the privacy preferences of the Identifiable Persons. Examples of when Cogent may seek information from others include, without limitation, evaluating employees, recruiting, benefit administration and succession planning.
Opt-Out Rights. Cogent will offer Identifiable Person(s) the opportunity to choose (opt-out) whether their Personal Data 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. In addition, where consent of Identifiable Persons or their representatives is required by law, contract or agreement for the collection, use, or disclosure of Personal Data, Cogent will request such consent and respect the Identifiable Person’s choice in such matters.
In certain limited or exceptional circumstances, in accordance with the Safe Harbor Principles, Cogent may disclose Personal Data without notice or the consent of the Identifiable Person. For example, this may occur when Cogent is required to disclose information by law or legal process or in the vital interests of the Identifiable Person, such as when life or health are at stake.
Opt-In Requirement. Except as provided by the Safe Harbor Principles or applicable law, an Identifiable Person must give affirmative permission (opt in consent) before Cogent will disclose Sensitive Data to a third party or use Sensitive Data for a purpose other than those for which it was originally collected or subsequently authorized by the Identifiable Person. Cogent will provide Identifiable Persons with reasonable mechanisms to exercise their choices.
3. Onward Transfer
Cogent takes commercially reasonable precautions to protect Personal Data against loss, misuse and unauthorized access, disclosure, alteration, destruction and theft. These precautions include password protections for online information systems and restricted access to Personal Data. Employees are responsible for assisting to maintain security through safeguarding Personal Data, e.g., by protecting passwords used to access the Cogent computer systems, by keeping paper records under lock and key when not in use, and by disposing of files and reports no longer needed in a secure manner.
5. Data Integrity
Cogent takes reasonable steps to keep Personal Data accurate, complete, and up-to-date. Each Identifiable Person is responsible for informing Cogent or its EU subsidiaries of any changes in Personal Data so that the information that Cogent possesses about him or her is accurate, complete and up-to-date. Cogent retains Personal Data only as long as necessary to meet the purposes for which it was collected or as required by law, contractual agreement or the Safe Harbor Principles. Cogent uses reasonable procedures, following retention guidelines, to ensure that it archives or destroys Personal Data no longer required for the purposes for which it was originally collected, unless otherwise agreed to by the Identifiable Person.
Cogent provides Identifiable Persons with a reasonable opportunity to examine their Personal Data, to challenge its accuracy and to have it corrected, amended or deleted as appropriate, subject to certain exceptions. Upon request, Identifiable Persons will be given reasonable access to the Personal Data Cogent possesses about them. Reasonable access means that requests for access are made during normal business hours, following Cogent standard procedures, and that the frequency of access requests is not excessive. If an Identifiable Person is denied access to Personal Data, Cogent will provide such Identifiable Person with the reason(s) for denying access and a contact point for further inquiries. If the Identifiable Person notifies Cogent that the Personal Data on file is incorrect and provides Cogent with appropriate supporting documentation, Cogent will either correct the Personal Data or direct the Identifiable Person to the source of the information for correction. If, upon review, Cogent believes that the existing Personal Data is correct, Cogent will inform the Identifiable Person. If the Identifiable Person continues to dispute the accuracy of the Personal Data, Cogent will note that dispute in the record of the Identifiable Person contained in the Cogent database upon written request.
The Safe Harbor Principles provides for some exceptions to the obligation to provide access to Personal Data. Access to confidential or proprietary information, such as business reorganization or succession plans, or where granting access has to be balanced against the privacy interests of others, may be restricted. In addition, access may be denied
- when the information requested relates to an ongoing investigation, litigation or potential litigation,
- where the burden or expense of providing access would be disproportionate to the risks to the privacy of the Identifiable Person or
- when the rights of persons other than the Identifiable Person would be violated.
7. Enforcement and Dispute Resolution
Cogent ‘s privacy practices are self-certified annually to the U.S. Department of Commerce. The Chief Administrative Officer is responsible for:
- Overseeing responses to inquiries and resolutions of complaints relating to the privacy of Identifiable Persons;
- Working with Cogent ‘s legal department to ensure Cogent’s ongoing compliance with applicable privacy laws and agreements, as well as any obligations Cogent may enter into voluntarily, such as the Safe Harbor Principles; and
This policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on Cogent’s web page www.trautmansguide.com.
EFFECTIVE DATE: July 31, 2010
If you would like to contact Trautmansguide.com directly about the Safe Harbor program, please send an e-mail to safeharbor@Trautmansguide.com.
14. CONDITIONS OF USE, NOTICES, AND REVISIONS
If you choose to visit Trautmansguide.com, your visit and any dispute over privacy is subject to this Notice and our Conditions of Use, including limitations on damages, resolution of disputes, and application of the law of the state of Washington. If you have any concern about privacy at Trautmansguide.com, please contact us with a thorough description, and we will try to resolve it. Our business changes constantly, and our Privacy Notice and the Conditions of Use will change also. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our Web site frequently to see recent changes. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.
COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™ Inc. reserves the right to change this privacy statement at anytime upon providing notification to visitors. This privacy statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any other person or entity. We do not undertake to provide you with personal notice of any changes. In the event of material changes, we will provide notice by means that are reasonable under the circumstances, such as by posting a notice on COGENT INFORMATION ANALYTICS, INC., dba Trautman’s Guide™’s web page, http://www.trautmansguide.com. Your continued use of the website following the posting of changes to this Privacy Statement means that you accept those changes.
EFFECTIVE DATE: July 31, 2010