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Privacy Policy (Safe Harbor)

Scope:

Gateway has developed the following privacy policy to protect individually identifiable information. This policy covers Gateway and applies to all individually identifiable information that Gateway obtains when a client uses a Gateway service. Gateway protects individually identifiable information as follows:

Disclosure:

Gateway will not sell, trade, or disclose to third parties any individually (either client or Gateway employee) identifiable information, derived from the use of any Gateway service, (except as required by subpoena, search warrant or other legal process or in the case of imminent physical harm to the customer or others). When Gateway uses other agents, contractors or companies to perform services on its behalf, Gateway will ensure that the company protects the individually identifiable information consistent with this policy.

Security:

Gateway has implemented technology and security features and strict policy guidelines to safeguard the privacy of identifiable information from unauthorized access or improper use, and we will continue to enhance our security procedures as new technology becomes available.

E-Mail Contents:

The company will not read or disclose to third parties private e-mail communications that are transmitted using Gateway services except as required to operate the service or as otherwise authorized by law.

Improper Conduct:

Gateway may use individually identifiable information to investigate and help prevent potentially unlawful activity or activity that threatens the network or otherwise violates the client agreement for that service.

Account Information:

Gateway honors requests from clients for changes in account information, such as name and password and will correct any such information that is inaccurate.

Safe Harbor Affirmation:

Gateway 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.  Gateway has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view Gateway’s certification, please visit  http://www.export.gov/safeharbor/. The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (FAQ) to enable U.S. companies to satisfy European Union (EU) law requirements for adequate protection of personal information transferred from the EEA to the United States. Gateway Ticketing Systems, Inc. adheres to the Safe Harbor Principles outlined below.

Privacy Principles:

The privacy principles in this policy are based on the Safe Harbor Principles.

Notice and Choice:

Gateway does not collect personal information directly from individuals in the EU. Personal information may exist in e-discovery information that is provided to Gateway from an EEA organization for processing. To the extent permitted in the Safe Harbor Agreement, we reserve the right to process personal information in the course of providing E-discovery ASP hosting services to our clients without the knowledge of individuals involved.

Onward Transfers and Disclosures to Agents:

Gateway requires any third parties to which we knowingly disclose information to, to enter into a written agreement that holds the third party to use the same degree of care and protection of the personal information.

Gateway will not knowingly 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 information in question is publicly available
  • The disclosure is reasonably necessary for the establishment or defense of legal claims

Data Security:

Gateway takes data security seriously and has put in place appropriate physical, electronic, and procedures to safeguard and secure the information we process

Data Integrity:

Gateway will use personal information only in ways that are compatible with the purposes for which it was collected, which is in the confines of e-discovery usage.

Access:

Upon request, Gateway will grant individuals reasonable access to personal information that it holds about them. In addition, Gateway will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Inquiries and complaints may be directed to support@gatewayticketing.com.

Enforcement:

Gateway utilizes the self-assessment approach to assure its compliance with our privacy statement. Gateway periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Safe Harbor Principles.

Changes in Practices:

Gateway will keep this policy current and will inform you of any changes that we make.

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