Assess Central

ASSESS CENTRAL PRIVACY POLICY
Safe Harbor Privacy Policy
January, 2012

Assess Central consistently strives to develop new and innovative products and services as part of our commitment to better serve our customers. We recognize that privacy is an important issue, so we operate ourselves in a manner consistent with the protection of your privacy. We developed this Privacy Policy pursuant to applicable law regarding the collection and use of personal information in those jurisdictions where we do business. This statement includes both Assess Central’s US-EU Safe Harbor Privacy Policy and the Website Privacy Policy. We urge you to read the Privacy Policy in its entirety and hope it will help you make an informed decision about sharing your personal information with us.

SAFE HARBOR

The Safe Harbor Program is a voluntary self-certification process for companies operating in the United States. Companies that certify represent that they adhere to the privacy standards for personal information received from the European Union that have been jointly accepted by the European Union Commission and the U.S. Department of Commerce. Personal information that Assess Central receives from the European Economic Union will be handled in accordance with the Safe Harbor Principles. Assess Central’s Safe Harbor Certification can be found at: http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list. For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s Website at http://www.export.gov/safeharbor.

SCOPE

This policy applies to all personal information received by Assess Central in the United States from the European Economic Union in any format including electronic, paper or verbal.

PRIVACY PRINCIPLES

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

NOTICE

Our Privacy Policy applies to all websites owned and operated by Assess Central and to any personal information collected by Assess Central. Where Assess Central collects personal information directly from individuals in the European Union, it will inform them about the purpose for which it collects and uses personal information. Assess Central will notify individuals how to contact us with any inquiries or complaints, the types of third parties we may share their personal information with, and the choice and means Assess Central offers for limiting the use and disclosure of their personal information.

CHOICE

Even after you have granted Assess Central your consent to collect personal information, you may opt-out of having your personal information collected. Assess Central will offer individuals the opportunity to choose (opt-out) whether their personal information is to be disclosed to a third party, or to be used for a purpose other than for which it was originally collected or subsequently authorized by the individual.

ONWARD TRANSFER

Assess Central will only transfer personal information about individuals to third parties where the third party has satisfactorily assured Assess Central that it will protect the personal information consistent with this Policy, or if they are located in the European Union or a country considered adequate for privacy by the European Union Commission, therefore required to comply with European Union data protection laws or substantially equivalent privacy laws, or the third party is Safe Harbor certified.

Assess Central will provide reasonable mechanisms for individuals to exercise their choice regarding their personal information.

ACCESS

Upon request, Assess Central will grant individuals reasonable access to their personal information. Assess Central will take reasonable steps to enable an individual to review their personal information in order to amend, correct or delete information.

SECURITY

Assess Central will take reasonable precautions to protect European Union personal information in its possession from loss, misuse, unauthorized access, disclosure, alteration and destruction.

DATA INTEGRITY

Assess Central uses personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by an individual. Assess Central will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.

ENFORCEMENT

Assess Central has established internal mechanisms to verify its ongoing adherence to this Policy. Any questions or concerns regarding the use or disclosure of personal information should be directed to the Assess Central Privacy Office at the address given below. Assess Central will investigate and attempt to resolve complaints and disputes regarding the use of personal information in accordance with the principles contained in this Policy. Assess Central has also agreed to participate in the dispute resolution program provided by the European Data Authorities.

LIMITATION ON SCOPE OF PRINCIPLES

Adherence to these Privacy Principles may be limited to the extent required to respond to a legal or ethical obligation, and to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the following person:

Sharon Nigro
President
12061 Lake Avenue
Lakewood, Ohio 44107
216-227-6272
216-227-1632 fax

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be amended periodically, consistent with the requirements of the Safe Harbor Principle. A notice will be available upon request.