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Safe Harbor Privacy PolicyOverview Safe Harbor, established by the European Union (EU) in 2000, is a way
for U.S. companies to transfer personal information from the European
Economic Area (EEA) (which includes the twenty-five member states of the
EU) to the United States without facing prosecution by European authorities
under European privacy laws. Certification will assure EU organizations
that our company adheres to the seven Safe Harbor principles. These principles
are Notice, Choice, Onward Transfer, Access, Security, Data Integrity,
and Enforcement. The manner in which The Hibbert Group complies with each
of these principles is listed below. Notice: Information is collected through, but not limited to, data file transmissions from The Hibbert Group's (THG) client or their business partner, websites , e-mail campaigns, returned mail / Business Reply Cards (BRCs), consumer inquiry by mail or phone, and coupon rebate programs. When THG receives consumer information from its customers in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such consumer information relates. Choice: All information collected online and offline by The Hibbert Group (THG) is subject to "opt-in" and "opt-out" mechanisms as defined by our customers. Onward Transfer: Personal consumer information collected on behalf of a client by The Hibbert Group (THG) or by a client or their business partner and provided to the THG will be used only for the client's business purposes. Sharing of information with third parties who are not identified as approved vendors in pursuit of the intended business scope is strictly prohibited. Access: Only those individuals, who need access to consumer information stored by The Hibbert Group (THG) or by an approved vendor of THG, in order to appropriately perform their jobs, will have access to consumer information. An individual has the right to receive confirmation from THG as to whether or not data relating to him/her is found in the THG database and to correct, amend or delete that information when it is inaccurate. Security: Each department within The Hibbert Group (THG) has an established business resumption plan that includes a strategic overview, plan activation procedures, response procedures, recovery procedures, and administrative procedures. THG's contracted recovery specialist audits the plan annually. All computers, servers, and mainframe computers require password and secure ID access. THG's Network monitors and reports unauthorized access points through the use of firewall and System OS technology. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of consumer information. Consumer information is accessible only by staff designated to handle online complaints or requests. All employees, both temporary and permanent, and consultants with access to consumer information obtained on THG Web Sites are also bound to adhere to this policy. Data Integrity: The Hibbert Group (THG) will only collect consumer information that is voluntarily submitted to the company by its clients, purchased on behalf of its clients, or procured on behalf of its clients through marketing activities. All consumer databases are defined by business rules for database and list maintenance relating to the management of consumer marketing programs/information as directed by the client. The Hibbert Group will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current. Enforcement: All employees of The Hibbert Group (THG), both temporary and permanent, including consultants and vendors, must adhere to the guidelines set forth in the Consumer Information Privacy Policy Agreements. All employees are required to sign this agreement acknowledging their responsibility to maintain consumer information confidentiality prior to accessing client information. THG employees receive training annually on how to safeguard the confidentiality of consumer information from misuse and unauthorized disclosure as set forth in this Statement. THG conducts audits of its privacy practices to verify adherence to this policy.
The Hibbert Group
The Hibbert Group has registered under the Direct Marketing Safe Harbor complaint resolution process. Should an individual be unable to resolve a complaint after having contacted THG, they may file their complaint with the Direct Marketing Association in writing at the following address: Safe Harbor Line The Hibbert Group is also subject to the jurisdiction of the US Federal
Trade Commission. Should an individual be unable to resolve a complaint
through The Direct Marketing Association's Safe Harbor Complaint process,
they may contact the Federal Trade Commission at the following address: Privacy on the Internet This Safe Harbor statement applies to all personal information received (including electronic, paper or verbal) by The Hibbert Group in the United States from the European Union. The Hibbert Group may disclose consumer information when required by law or in the good faith belief that such action is necessary. We reserve the right to revise this Statement as necessary.
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