Tele-Town Hall Safe Harbor Privacy Policy

Introduction

Tele-Town Hall LLC™, and its subsidiary and affiliated companies (“TTH”, “we”, “us”, or “our”) recognize that privacy is very important to our customers, and we pledge to protect the security and privacy of any personal information that customers provide to us. This includes customer’s names, addresses, telephone numbers, email addresses and any information that can be linked to an individual. Not only does TTH strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. Tele-Town Hall LLC™ complies with the U.S.-EU 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. Tele-Town Hall™ has certified that it adheres to Safe Harbor Privacy Principles (“Principles”) of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Tele-Town Hall LLC’s certification, please visit www.export.gov/safeharbor.

If there is any conflict between the language in this Policy and the Principles, the Principles will govern. This Policy outlines our general procedures and practices for implementing the Principles, including the types of information we gather, how we use it, and the choices affected individuals have regarding our use of, and their ability to correct, that information.

Tele-Town Hall™ utilizes a patented mass automated variable speed dialing system with a voice over IP (Internet Protocol) connection to dial out to thousands of phone numbers from a pre-selected list of participants, submitted to us by our customers. When a list is loaded into the Tele-Town Hall™ system, our customer retains complete ownership over their data. Every person who answers the phone will be played a pre-recorded Introductory Message that functions as an automated operator inviting each household to remain on the phone to participate in a Tele-Town Hall™ with the “star” Speaker. Participants will be automatically connected to a live event in progress until the dialing process is complete.

This Policy applies to all personal information including on-line, off-line, and manually processed data. For purposes of this statement, “personal information” means information that: i) is transferred from the EU to the United States; ii) is recorded in any form; and iii) can be linked to an individual. It does not include personal information that pertains to a specific individual, but from which that individual could not reasonably be identified.

Privacy Principles

Notice and Choice

To the extent permitted by the Safe Harbor Agreement, we reserve the right to process personal information in the course of providing professional services to our customers without the knowledge of individuals involved. Where we collect personal information directly from individuals in the E.U., we inform them about the types of personal information we collect from them, if any, the purposes for which we collect and use it, and the types of non-agent third parties to which we disclose that information, if any. We also inform those individuals about the choices and means, if any, we offer individuals for limiting the use or disclosure of their information.

Disclosures

TTH will not disclose an individual’s personal information to third parties, except when one or more of the following conditions is true:

  • We have the individual’s permission to make the disclosure;
  • The disclosure is required by law or professional standards;
  • The personal information in question is publicly available;
  • The disclosure is reasonably necessary for the establishment or defense of legal claims.

Data Security

TTH will take reasonable precautions to protect personal information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of personal information, either for its own purposes or on behalf of our customers, TTH has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal information we process. However, we cannot guarantee the security of personal information transmitted to TTH via the Internet.

There has never been a security breach and we take every effort to insure there never will be. However, TTH is not responsible for unauthorized access by illegal means, in the absence of negligence by TTH or its affiliates.

The customer is responsible for the security of the user names and personal identification numbers

(PIN codes) that are issued to them to access the phone broadcasting and service interface.

If security has been breached, customers are advised to contact our customer service department at

202-237-8313 to request the PIN numbers be changed immediately.

Data Integrity

TTH will process personal information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, TTH will take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.

Access and Correction

If an individual becomes aware that personal information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her personal information, the individual may contact us using the contact information below. We will take reasonable steps to permit individuals to correct, amend, or delete personal information that is demonstrated to be inaccurate. The individual will need to provide sufficient identifying personal information, such as full name, address, birth date, and driver license number or government-issued identification card number. We may request additional identifying personal information as a security precaution. In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement.

Enforcement and Dispute Resolution

TTH utilizes the self-assessment approach to assure its compliance with our privacy statement. TTH periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles. We encourage interested persons to raise any concerns with us using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.

With respect to any complaints relating to this Policy that cannot be resolved through our internal processes, we have agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities to resolve disputes pursuant to the Safe Harbor Principles. If we or such authorities determine that we did not comply with this Policy, we will take appropriate steps to address any adverse effects and to promote future compliance. Any person who we determine is in violation of our privacy policies will be subject to disciplinary process.

Privacy Statement Changes

TTH reserves the right to change this Privacy Policy at anytime, consistent with the requirements of the Safe Harbor Agreement. We will post any revised Policy on this Site, or a similar Site that replaces this Site. Please review this policy each time you visit our website to stay current, as continued patronage and use of this website denotes your assent to any modifications.

Information Subject to Other Policies

We are committed to following the Principles for all personal information within the scope of the Safe Harbor Agreement. Information obtained from or relating to customers or former customers is further subject to the terms of any privacy notice to the customer, any contract or other agreement with the customer, and applicable and enforceable laws.

Contact Information

Questions or comments regarding this Policy should be submitted to the TTH Privacy Policy Department by mail or e-mail as follows:

  • Tele-Town Hall, LLC™
  • Attn: Privacy Policy Dept.
  • 4600 North Fairfax Drive
  • Suite 802 Arlington, VA 22203
  • Email: privacy@teletownhall.com
  • EFFECTIVE DATE: January 1, 2010