We
self-certify compliance with:
Adopted:
April 24th, 2012
At APX,
Inc and its affiliated entities. (collectively or individually referred to as
"APX" or "we"), we recognize that privacy is important to you. This Privacy
Policy applies to all of the products, services, and websites offered by
APX
APX
complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss 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 and Switzerland. APX 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 APX's certification, please visit http://www.export.gov/safeharbor.
Notice:
Information we collect and how we use
it
APX
collects and uses personal and other information in a number of ways.
Registration
with APX
When you sign up for a particular service that may require registration, we ask
you to provide personal contact information such as your name, address,
telephone number and email address. This information may also include
basic account information for billing or other purposes.
Information
for Processing from Other Business Organizations
APX may receive information from other business organizations such as our
clients for the purpose of providing services to these organizations.
Some of this information may be non-public personal information or confidential
account information. Generally, we process this information on their
instructions and subject to confidentiality provisions.
Information
Automatically Logged
A number of APX applications use web server logs and similar tools to help
diagnose problems with the server, to administer the website, and to enhance
security or authenticate users. Server logs are analyzed by a commercial tool to
provide simple access demographics, including "New vs. Returning Visitors," "Top
Visitors," "Top Geographic Regions,", and other statistical
reports.
User
Communications
When you send email or other communications to APX, we may retain and use
those communications in order to process your inquiries, respond to your
requests, and improve our services.
Cookies
Our systems may use cookies to keep track of the state of your session and may
also use cookies to deliver content specific to your interests. No personal
information is stored in cookies. If cookies are disabled, certain applications
in the protected portion of our systems may not work properly.
Other Purposes and Sharing
It is
APX's policy not to use or disclose confidential or non-public information
received from clients or end-user customers except in connection with the
provision and improvement of APX services. Such uses or disclosures may
include, for example, those that are usual, appropriate, or acceptable to carry
out the APX service for which the information was given or a transaction related
thereto, to maintain accounts, to provide confirmations and statements, to
provide access to data services, and for record keeping purposes. In
addition to the uses and disclosures set forth above, APX may use information
you provide or it otherwise receives for:
auditing,
research, and analysis in order to maintain, protect, and improve our services;
ensuring
the technical functioning of our network;
satisfying
any applicable law, regulation, legal process, or enforceable governmental
request;
enforcing
applicable Terms of Use, including investigation of potential violations
thereof;
detecting,
preventing, or otherwise addressing fraud, security or technical issues; or
protecting
against harm to the rights, property, or safety of APX, its users or the public
as required or permitted by law.
Sharing
of Aggregated and Non-Personal Information
We may share with third parties certain pieces of aggregated, non-personal
information. Such information does not identify you individually or compromise
any aspect of confidential information or transactions.
International
Users and Location of Data Processing
APX processes personal, confidential, and non-public information on our servers
in the United States of America and in other countries where data protections
may differ and in some cases be less adequate than those found, for example, in
the European Union or Switzerland. In some cases, we may process such
information on a server outside your own country. Individuals outside the
United States who submit personally identifiable information via this website
acknowledge and agree that the information submitted will be forwarded to the
United States or other jurisdictions for processing in connection with the
purposes for which it has been supplied.
Links to
Other Websites
Our websites may contain (resource) links to other websites. APX is not
responsible for the privacy practices or the content of such websites. Users
linking to other websites are encouraged to verify the privacy practices of the
other websites.
Choice:
Options Concerning Information We Collect
APX will
not collect or use information for purposes other than those described in this
Privacy Policy without your consent. You can decline to submit personal
information to any of our services, in which case APX may not be able to provide
those services to you.
Administrative
and Marketing Communications: We Do Not Share with Third Parties for Their
Marketing Purposes
It is the policy of APX not to disclose confidential or non-public information
to third parties for their direct marketing purposes.
APX does
not endorse or promote offers from third party advertisers and will not share
your information with them.
APX may
from time to time, in accordance with this Privacy Policy, use personal,
confidential, or non-public data to inform a customer or accountholder about
products and services that APX expects may be of interest to them.
Individuals may object to any such data being used for such marketing purposes
by contacting us in writing at the address indicated
below.
Clients
and end-user consumers consent to receiving administrative and related
electronic communications related to our relationship.
Onward
Transfer: Vendor and Supplier Information Sharing
APX may
disclose information to third parties such as vendors and suppliers who may act
as our agent and with third parties on whose behalf we are collecting such
information where such sharing is required by our business relationship.
Such sharing occurs subject to appropriate confidentiality obligations. We
require our vendors and suppliers to agree to process such information based on
our instructions and any other appropriate confidentiality and security
measures.
Access:
Your Right to Know and Correct the Information We Hold
APX
strives to ensure that personal information is kept accurate and up to date. APX
kindly requests its clients and end user customers to assist APX in complying
with this obligation by informing APX of any changes to their personal
information. Clients and end-user customers have the reasonable right to
request details of the personal information that APX holds and to request the
deletion or modification of any inaccurate personal information held by
APX. Requests to access, modify, or delete such personal information
should be sent in writing to the address indicated below.
Security:
Our Efforts to Protect Information
APX takes
reasonable precautions to protect personal, confidential, and non-public
information. APX has established an information security program setting
forth standards for maintaining administrative, technical and physical
safeguards to govern information in our care, custody, or
control.
It is
APX's policy to restrict access to confidential, non-public, and personal
information to those employees who need to know such information in order to
provide APX services or as otherwise appropriate and consistent with this
Privacy Policy.
No data
transmissions over the Internet can be guaranteed to be 100% secure.
Consequently, we cannot ensure or warrant the security of any information you
transmit to us and you do so at your own risk. Despite our efforts, we cannot
guarantee that information we process may not be accessed, disclosed, altered,
or destroyed by breach of our security measures. In the event of a
security incident, we will notify our clients or end-user customers in
accordance with applicable law.
Questions
and Enforcement
APX
regularly reviews its compliance with this Privacy Policy. Please feel free to
direct any questions or concerns regarding this Privacy Policy or APX's
treatment of personal, confidential, or non-public information by contacting us
through this website or by writing to us at the address indicated
below.
When we
receive formal written complaints at this address, it is APX's policy to contact
the complaining user regarding his or her concerns.
APX will
cooperate with relevant data protection authorities in the investigation and
resolution of complaints brought under the Safe Harbor Principles where
applicable.
Changes
to This Privacy Policy
If in the
future we change this Privacy Policy, we will post the new policy on this
website. If this policy is somehow materially less restrictive or protective of
your privacy than the current policy, we will not apply the less protective
aspects of the revised policy to information you have previously provided to us
without first obtaining your consent. If we have a way of contacting you
electronically, we will do so in the way you have instructed us to obtain your
consent. We reserve the right to change this Privacy Policy in the future. Your
continued use of this website following a change in the Privacy Policy
represents consent to the new policy to the fullest extent permitted by law.
We encourage you to periodically review this Privacy
Policy.
Contacting
APX
You can contact APX through our website or as follows:
by
telephone at (201) 748-7900
or in
writing at:
APX
Attn:
General Counsel
31 W 34th Street, Suite 8005
New York, NY 10001
USA