1.0 Introduction
The purpose of this document is to inform you about the type of information that ASI Group (ASI) gathers on individuals who utilize its electronic services, how it uses this information, whether it is disclosed to any third parties, your ability to modify/remove the information and how that information is protected.
1.1 Effective Date
The Effective Date of this Privacy Policy is June 1, 2010.
2.0 Personal Information Collection and
Usage
ASI collects, stores and may use information gathered on individuals that utilize its Internet-based and email-based services. The extent of the information gathered and used may vary widely based on the information service utilized by the individual. In all circumstances, ASI may collect and possibly share information in order to investigate, prevent, or take action regarding illegal activities, situations creating potential threats to the physical safety of any person, suspected fraud, violations of ASI's terms of use, or as otherwise required by law. ASI may respond to subpoenas, court orders, or legal process and may choose to establish or exercise its legal rights or defend against legal claims. At any time, the organization that holds a license to an online service may request information for its use for internal purposes. ASI shall not be responsible for actions related to information used by the licensee. ASI’s parent company and affiliates may have access to the information for legitimate business purposes and will maintain the information confidential as held by ASI.
2.1.1 Airline Insider
Airline Insider is an internet-based database of safety and security information regarding commercial airlines. Data gathered on users of the Airline Insider is utilized for statistical monitoring of session usage and legal purposes on behalf of ASI, its designated agents, affiliates, and the organization that hold the license. This information will not be used for marketing purposes or sold/transferred to third-parties for marketing purposes. Archived information regarding session usage may be stored for an extended period of time.
2.1.2 ASI Research Tool (ART)
ART is an internet-based research tool utilized by organizations for background checks. Data entered by users may contain personally identifiable information regarding the individual on whom the background check is being conducted. Personally identifiable information contained in the data will not be used for marketing purposes or transferred to third-parties for marketing purposes. Data gathered on users of the ASI Research Tool (ART) and data entered into the system is utilized for statistical monitoring of session usage and legal purposes on behalf of ASI, its designated agents and affiliates and the organization that holds the license. This information will not be used for marketing purposes, sold, or transferred to third-parties for marketing purposes. Archived information regarding session usage may be stored for an extended period of time. At any time, the organization that holds the license to the service may request information for its use for internal
purposes.
2.1.3 ASI Essentials
ASI Essentials is an internet-based database of safety and security information regarding cities around the world. Data gathered on users of ASI Essentials is utilized for statistical monitoring of session usage and legal purposes on behalf of ASI, its designated agents and affiliates and the organization that holds the license. This information will not be used for marketing purposes, sold, or transferred to third-parties for marketing purposes. Archived information regarding session usage may be stored for an extended period of time.
2.1.4 ASI Travel Security Manager
The ASI Travel Security Manager (TSM) is a service that aggregates employee travel reservations on behalf of the licensee. The purpose of the service is to enhance the ability of the subscribing organization to protect the safety and security of its employees. Data is primarily obtained from travel agencies approved by the licensee and may contain personally identifiable information. ASI will limit use and access to personally identifiable information contained in the data to those activities that directly support the licensee with regard to protecting the safety and security of its employees. Personally identifiable information contained in the data will not be used for marketing purposes or transferred to third-parties for marketing purposes. Information gathered by the ASI Travel Security Manager related to the approved users of a licensee is utilized by ASI for statistical monitoring of session usage and legal purposes on behalf of ASI, its designated agents and affiliates and the organization that holds the license. This information will not be used for marketing purposes, sold, or transferred to third-parties for marketing purposes. Archived information regarding session usage may be stored for an extended period of time.
2.1.5 HOT SPOTS
Hot Spots is a free subscription-based briefing report sent via email Monday through Friday. Subscriptions are initiated only by request by the individual. Third-party requests to add an individual to the Hot Spots mailing lists will not be accepted. The individual requesting the subscription is required to actively supply certain information to ASI before a subscription request will be accepted. This information includes, but is not limited to: Name, Organization Name, Address, City, State, Postal Code, Country, Telephone Number, Fax Number, and E-Mail Address. Individuals should be aware that failure to submit required information or the provision of incomplete information may preclude ASI from initiating a subscription to the Hot Spots report. Under no circumstances is this information sold or otherwise transferred to a third-party. Individuals acting in a business capacity may receive a marketing-related email from ASI upon submission of their subscription request. In addition, individuals acting in a business capacity may have their personal business information stored in retrievable form by ASI for an extended period of time. Individuals may request to review, change, or remove personal information that is stored in retrievable form in ASI’s databases by following the processes set out in Section 5.0 of this document. Subscribers to the Hot Spots mailing list may receive occasional marketing-related e-mail messages from ASI, its parent company or affiliates.. At any time, a subscriber to Hot Spots may request a change to their Hot Spots subscription (e.g.: email address change) or removal (opt-out) from the Hot Spots mailing list by sending an email to hotspots@asigroup.com or by formal written letter to:
HOT SPOTS
ASI Group
2925 Briarpark, Suite 1100
Houston, Texas 77042
2.1.6 World Watch® Online
World Watch is an internet-based database of safety and security information regarding countries and cities around the world. Data gathered by ASI relating to users of World Watch® Online is utilized by ASI for statistical monitoring of session usage and legal purposes on behalf of ASI, its designated agents and affiliates and the organization that holds the license. This information will not be used for marketing purposes, sold, or transferred to third-parties for marketing purposes. Archived information regarding session usage may be stored for an extended period of time.
2.1.7 Information Requests via ASI Website or Email
ASI may utilize personal information actively submitted to its public websites for marketing purposes. This information may include, but is not limited to: name, address, title, employee number, telephone number, fax number and email address. Individuals acting in a business capacity may have their personal business information stored in retrievable form by ASI for an extended period of time. Individuals may request to review, change, or remove personal information that is stored in retrievable form in ASI’s databases by following the processes set out in Section 5.0 of this document. Under no circumstance shall ASI sell or transfer personal information actively entered to its public websites to a third-party for marketing purposes. Individuals who do not wish to share personal information should not actively submit such information to ASI. Individuals should be aware that failure to submit required information or the provision of incomplete information may preclude ASI from fulfilling
a particular request.
3.0 Security
ASI is committed to ensuring the security of your information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. We use encryption when collecting or transferring sensitive data such as travel reservations.
4.0 Transfer and Access of Data
Personal information gathered by ASI through its public and subscription-based websites may be transferred across state or country borders. All such data transfers shall be in accordance with the terms outlined in this document.
5.0 Review, Modification and Removal of Data
An individual may request to review, change, or remove personal information that is stored in retrievable form in ASI’s databases by formal written request to ASI. Information is considered to be in retrievable form when it is "retrievable in the ordinary course of business" by taking steps that are taken on a regular basis in the conduct of ASI’s business activities with respect to that information, or by steps that ASI is capable of taking with the procedures it uses on a regular basis in the conduct of its business.
Formal written requests for review, change or
removal of personal information should be directed to:
Privacy Issues
ASI Group
2925 Briarpark, Suite 1100
Houston, Texas 77042
6.0 Safe Harbor and Enforcement
ASI is an adherent to the safe harbor framework developed by the U.S. Department of Commerce in coordination with the European Commission. The safe harbor framework provides guidance for U.S. organizations on how to provide "adequate protection" for personal data from Europe as required by the European Union's Directive on Data Protection. ASI undergoes an annual privacy policy review and self-certification process as part of its adherence to the safe harbor principles.
Under the Safe Harbor's Enforcement Principle, organizations self-certifying to Safe Harbor must establish an independent recourse mechanism available to investigate unresolved complaints. ASI has chosen to utilize the European Data Protection Authorities (DPA) in fulfillment of the Enforcement Principle. This means that ASI commits to cooperate with the DPAs in the investigation and resolution of complaints brought under the safe harbor. In addition, ASI agrees to comply with any advice given by the DPAs with regard to specific action needed to comply with the Safe Harbor Principles, including remedial or compensatory measures for the benefit of individuals affected by any non compliance with the principles.
7.0 Use of “Cookies”
A “cookie” is a piece of information stored temporarily in an individual’s browser memory space or placed on the individual computer's hard drive (stored cookie). Cookies may be used in some circumstances on some information systems, but are not used for marketing purposes by ASI, its designated agents and affiliates. Cookies utilized by ASI are not used to track usage outside of ASI websites.
8.0 Third-Party Websites
Links to third-party websites are provided as a convenience to the user. When linking to a third-party website, the user will leave the system administered by ASI. Control and content of third-party websites are provided by the owner of that website and not ASI. ASI does not endorse or make any representation regarding third-party websites and cannot be held responsible for content, control or usage in any manner whatsoever. Use of third-party sites should be done entirely at the user’s own risk.
9.0 Questions / Comments
Informal questions or comments regarding ASI’s online privacy practices should be directed to privacy-issues@asigroup.com.
Questions or comments requiring a formal response from ASI should be directed to:
Privacy Issues
ASI Group
2925 Briarpark, Suite 1100
Houston, Texas 77042
10.0 Changes to ASI Privacy Policy
In accordance with the California Online Privacy Protection Act of 2003, ASI has created a Privacy Policy Update Log ("PPUL"). The PPUL constitutes a public notification mechanism to announce changes to this policy document. The PPUL will note the date of any change to the ASI Privacy Policy and document the nature of the change. The PPUL will only document changes after June 30, 2004. Consumers may access the PPUL by visiting the following URL: http://www.asigroup.com/privacy_policy_blog.htm
