JAS WorldWide

JAS Worldwide S.a.r.l
Safe Harbor Privacy Policy

JAS has certified that we abide by the Safe Harbor privacy principles, as set forth by the United States Department of Commerce, regarding the collection, storage, transfer, use and other processing of consumer and customer personal information transferred from the European Economic Area (“EEA”) to the United States.  For purposes of this Safe Harbor Privacy Policy (“Policy”), “Personal Information” means information that (i) is transferred from the EEA to the United States, (ii) is recorded in any form, (iii) is about, or relates to, an identified or identifiable consumer or customer, and (iv) can be linked to that consumer or customer. This Policy outlines our general policy and practices for implementing the Safe Harbor privacy principles for online and offline Personal Information.

Safe Harbor Privacy Principles
JAS’s practices regarding the collection, storage, transfer, use and other processing of Personal Information comply with the Safe Harbor principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight.

Notice
We notify our consumers and customers located in the EEA about the purposes for which we collect and use Personal Information, the types of third parties to which we disclose the information, the choices consumers and customers have for limiting the use and disclosure of their information, and how to contact us about our practices concerning Personal Information.

Purpose of Collection and Use of Personal Information
JAS collects certain Personal Information such as name, email address, postal address and telephone number. We do not collect sensitive Personal Information, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or other sensitive information as defined by the Safe Harbor framework.
We use Personal Information (i) to establish and maintain of our relationship with you, (ii) to respond to your requests and inquiries, (iii) to meet certain legal, regulatory, insurance, security and processing requirements, and (iv) otherwise with your consent.

JAS shares Personal Information with and among JAS’s subsidiaries and affiliates. With the exception of JAS’s subsidiaries and affiliates with whom we share Personal Information solely pursuant to, and in connection with, the services performed on your behalf, JAS does not share Personal Information with third parties.  We do not use Personal Information for purposes incompatible with the purposes for which the information was originally collected without notifying the relevant consumers or customers of such uses and offering an opportunity to opt out.
In addition, we may disclose Personal Information (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on an enforceable government request or as may be required under applicable law, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

Onward Transfer of Personal Information
We do not share Personal Information with any non-agent third parties; provided, however, we may share your Personal Information with our subsidiaries and affiliates pursuant to, and in connection with, the services performed on your behalf.  JAS will obtain assurances from its agents that they will safeguard Personal Information consistently with this policy.  Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Hungary and Switzerland). Where JAS has knowledge that an agent is using or disclosing Personal information in a manner contrary to this Policy, JAS will take reasonable steps to prevent or stop the use or disclosure.

Access to Personal Information
JAS provides consumers and customers with reasonable access to the Personal Information maintained about them. We also provide a reasonable opportunity to correct, amend or delete that information where it is inaccurate. We may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Safe Harbor principles. You may access your profile page via the Manage Account link accessible any time you are logged into the Website.

Security
JAS maintains reasonable administrative, technical and physical safeguards to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity
JAS takes reasonable steps to ensure that Personal Information that we collect is relevant for the purposes for which it is to be used and that the information is reliable for its intended use and is accurate, complete and current. We depend on our consumers and customers to update or correct their Personal Information whenever necessary.

Enforcement, Oversight and Dispute Resolution
JAS has established procedures for periodically verifying implementation of and compliance with the Safe Harbor principles. We conduct an annual self-assessment of our practices with respect to Personal Information to verify that representations we make about our Personal Information privacy practices are true and that related privacy policies have been implemented as represented.

Any questions or concerns regarding the use or disclosure of personal information should be directed to the JAS Privacy Office at the address given below. JAS 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. For complaints that cannot be resolved between JAS and the complainant, JAS has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.
Contact Us
 JAS Worldwide S.a.r.l
 Attn: Privacy Officer
 5424 Glenridge Drive N.E.
 Atlanta, GA 30342
 USA

You may contact us at info@jas.com  if you wish to correct or change any information about you that we may have collected or if you wish to opt-out of receiving any communications from us.

This Safe Harbor Privacy Policy was last revised on and is effective as of September 24, 2009.

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Contact Us

Phone: +1 (770) 688-1240

Fax: +1 (770) 688-1233