Privacy Policy
Xpedite Systems, Inc. d/b/a Premiere Global Services, ("PGS") recognizes and respects the
importance of protecting individuals' privacy. To that end, we have
adopted the principles set forth in this Privacy Policy ("Policy")
to govern our use and disclosure of individuals' personally
identifying information ("Personal Information").
Scope This
Policy applies to all Personal Information that PGS collects or
receives, whether manually or digitally processed.
Our
Services PGS provides high-volume and value-added
electronic mail, facsimile and voice messaging services ("Services")
for customers located around the globe. Our customers retain PGS
to transmit messages and provide information to their recipients
("Recipients"). In the course of those Services, we are
provided by our customers with Personal Information relating to
their Recipients. In all cases we simply act as agent for our
customers and at their direction. At no time do we do anything other
than format or transmit the content of the messages we are asked to
send. Our Customer Service Agreement requires that our customers
comply with all applicable personal-data privacy laws in compiling
and providing us with the Recipient Personal Information. Through
some of our value-added services we may collect Personal Information
from Recipients. For example, with messageREACH®, we store
attachments to messages provided to us by our customer on our
server. When the Recipient decides to access the attachment, we are
able to report back to our customer that this access has taken
place. However, at all times we use any Personal Information we
receive only for the purposes and at the direction of the customer
associated with the respective Recipient. In addition to facsimile
and electronic mail, we also offer voice messaging through our
voiceREACHSM service. With voiceREACH, we dial Recipients
whose telephone numbers our customers have provided us, in order to
deliver pre-recorded messages supplied by our customers. PGS
complies with all applicable laws governing the time of day of our
voiceREACH calls. We also require our customers to provide
appropriate identifying and contact information at the beginning or
end of the message through which the Recipient may respond to have
his or her number removed from the customer's list or obtain contact
information for the customer. Where we collect Personal Information
(such as the fact that a call was successfully completed, that a
Recipient has requested to receive no further calls, or that the
Recipient has a new number), we provide it only to the customer on
whose behalf the call was made.
Other
Information Collection You also may provide us with Personal
Information when you contact us with a question or concern about
this Policy or about our Services. If you choose to provide your
Personal Information in this context, we will use it only to respond
to your inquiry or otherwise as required by law.
Transfer
of Personal Information As noted above, we utilize the
Personal Information of Recipients only as directed by our customers
in the performance of the Services. We do not disclose the Personal
Information to third parties except to the specific customer with
whom the Recipient is associated unless otherwise required by law.
Access
to Personal Information Individuals seeking access to their
Personal Information that we have received from a customer must
contact the customer directly. PGS requires messages to contain
the name or contact information of the customer on whose behalf the
message was sent. We also would be happy to provide that contact
information to any interested Recipient upon request.
Security We
utilize reasonable and appropriate protections to ensure that
Personal Information in our care is not misused or accessed without
authorization. Personal Information is stored on our own servers,
with access restricted to those employees or contractors who have a
need for such access to perform a legitimate business function
relating to the Services or for maintenance, internal security or
related issues. Moreover, we generate audit logs that record all
access and use of Recipients' Personal Information stored in our
databases. Any contractor whom we retain to provide services for us
and who will have access to Personal Information must agree in
writing to abide by the terms of this Policy.
Data
Integrity We only use Personal Information that is necessary
to perform the Services requested. Occasionally, a customer provides
us with more Personal Information than is necessary for that purpose
(for example, providing us with a name, street address and e-mail
address, when only the name and e-mail address are necessary). In
those cases, we identify and utilize only those data that are
needed. The rest remain secure and unused until destroyed or
returned to the customer. We also only store Personal Information
when specifically requested to do so by a customer or as part of our
ordinary back-up, archiving process. Archived files are secured as
set forth in paragraph 8 above and are destroyed on a regular cycle.
Review
of Compliance PGS will review its compliance with this
Policy on a periodic basis.
Acquisition,
Merger or Bankruptcy In the event PGS, its parent or any
of its affiliates or subsidiaries is acquired by another entity, or
merges with a third party, the successor entity will be bound to
respect the provisions of this Policy with regard to any Personal
Information in its possession prior to the acquisition or merger. In
the event of bankruptcy, the provisions of applicable law will
apply.
Enforcement Concerns
regarding our adherence to this Policy should be raised first with
our Privacy Compliance Officer, through the contact information
provided below.
European
Union Safe Harbor Compliance Statement European data-privacy
laws protect Personal Information that is transferred from the
European Union to the United States. The U.S. and E.U. have entered
into a "Safe Harbor" that allows U.S. entities receiving
Personal Information from the E.U. to satisfy those obligations. The
provisions of this Policy satisfy the Safe Harbor Principles.
PGS has certified that compliance with the United States
Department of Commerce. Because, as explained above, we simply use
the Personal Information provided to us to deliver messages and
provide related services for our customers, under the Safe Harbor
our customers remain responsible for that Personal Information with
respect to the individuals concerned. Any additional Personal
Information we collect as a result of our Services is provided only
to the customer for whom it is collected. PGS's compliance with
this Policy is subject to the ultimate authority of the United
States Federal Trade Commission, to which complaints that are not
adequately resolved through the procedure set forth in paragraph 12
above also may be directed.
Do
Not Call Policy PGS strives to maintain the highest
standards of ethical conduct and is committed to complying with all
federal and state telemarketing legislation. No employee or agent of
PGS shall engage in conduct that violates the terms of the
Telephone Consumer Protection Act of 1991, applicable rules, or
state telemarketing regulations. Our personnel are trained to comply
with this policy. At your request, PGS will be happy to place
your telephone numbers on our Do Not Call List. We will note your
request immediately, but it may take up to 30 days to remove your
information from active lists. You can make your request by calling
866-849-3243, or by writing to us at: 100 Tormee Drive, Tinton
Falls, NJ 07712. When you make a request be sure to include your
name, address and all telephone numbers (phone and fax numbers, if
applicable) you want to be included on our list. You'll remain on
our "Do Not Call" List for 10 years, unless you ask to be
removed. If your information changes, please notify us of the new
name, address, and telephone number(s) in order to remain on the Do
Not Call List. If you would like us to remove you from our Do Not
Call List so you may receive telephone solicitations by PGS or
its customers, notify us by contacting Customer Service at the
number indicated above. You may also send us correspondence by mail
at the address indicated above. If your name, address or telephone
number ever changes, you must give us your new information for your
"Do Not Call" status to remain in effect.
Corporate
Privacy Officer To contact our Corporate Privacy Officer when
indicated by this Policy or to address questions regarding PGS's
privacy practices, please e-mail privacy@premiereglobal.com
or call 1-800-966-3297.
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