Starweaver Group, Inc. (“Starweaver”) respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Not only does Starweaver 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. This Safe Harbor Privacy Policy (the “Safe Harbor Privacy Policy”) sets forth the privacy principles Starweaver follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.

SAFE HARBOR

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, Starweaver adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”).

SCOPE

This Safe Harbor Privacy Policy (the “Safe Harbor Privacy Policy”) applies to all personal information received by Starweaver in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal.

DEFINITIONS

For purposes of this Safe Harbor Privacy Policy, the following definitions shall apply:

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Starweaver or to which Starweaver discloses personal information for use on Starweaver’s behalf.

“Starweaver” means Starweaver Group, Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of Starweaver to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Starweaver will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The privacy principles in this Safe Harbor Privacy Policy have been developed based on the Safe Harbor Principles.

NOTICE: Where Starweaver collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which Starweaver discloses that information, the choices and means, if any, Starweaver offers individuals for limiting the use and disclosure of personal information about them, and how to contact Starweaver. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Starweaver, or as soon as practicable thereafter, and in any event before Starweaver uses or discloses the information for a purpose other than that for which it was originally collected.

Where Starweaver receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: Starweaver will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Starweaver will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Starweaver will provide individuals with reasonable mechanisms to exercise their choices.

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

TRANSFERS TO AGENTS: Starweaver will obtain assurances from its agents that they will safeguard personal information consistently with this Safe Harbor Privacy 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), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Starweaver has knowledge that an agent is using or disclosing personal information in a manner contrary to this Safe Harbor Privacy Policy, Starweaver will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, Starweaver will grant individuals reasonable access to personal information that it holds about them. In addition, Starweaver will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: Starweaver will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: Starweaver will conduct compliance audits of its relevant privacy practices to verify adherence to this Safe Harbor Privacy Policy. Any employee that Starweaver determines is in violation of this Safe Harbor Privacy Policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Starweaver Privacy Office at the address given below. Starweaver will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Safe Harbor Privacy Policy. For complaints that cannot be resolved between Starweaver and the complainant, Starweaver has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

1. for disputes involving all personal information received by Starweaver from Switzerland, Starweaver has agreed and to cooperate with the Swiss FDPIC;
2. for disputes involving employment-related personal information received by Starweaver from the EEA, Starweaver has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
3. for disputes involving all other personal information received by Starweaver from the EEA, Starweaver has agreed to TRUSTe dispute resolution. Individuals who submit a question or concern to Starweaver and who do not receive acknowledgment from Starweaver of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the TRUSTe Safe Harbor Dispute Resolution Program on the Internet, by mail or by fax. Inquiries by mail or fax should identify Starweaver as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether TRUSTe may share the details of the inquiry with Starweaver. TRUSTe will act as a liaison to Starweaver to resolve these disputes.
   1. a. http://watchdog.truste.com/pvr.php?page=complaint&url
       b. Fax: 415-520-3420
       c. Mail: Watchdog Complaints, TRUSTe, 55 2nd Street, 2nd Floor, San Francisco, CA, USA 94105
   2. For information about TRUSTe or the operation of TRUSTe’s dispute resolution process, visit TRUSTe on the Internet(http://watchdog.truste.com/pvr.php?page=complaint&url) or request this information from TRUSTe by mail or fax using the contact information listed above. The TRUSTe dispute resolution process shall be conducted in English.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by Starweaver to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

INTERNET PRIVACY

Starweaver sees the Internet and the use of other technology as valuable tools to communicate and interact with consumers, employees, business professionals, business partners, and others. Starweaver recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the “Internet Privacy Policy”) governing the treatment of personal information collected through web sites that it operates. With respect to personal information that is transferred from the European Economic Area or Switzerland to the U.S., the Internet Privacy Policy is subordinate to this Safe Harbor Privacy Policy. However, the Internet Privacy Policy also reflects additional legal requirements and evolving standards with respect to Internet privacy. Starweaver’s Internet Privacy Policy can be obtained by contacting the company at helpdesk@starweaver.com.

CONTACT INFORMATION

Questions or comments regarding this Safe Harbor Privacy Policy should be submitted to the Starweaver Privacy Office by mail to:

Starweaver Privacy Office

Starweaver Group, Inc.
1122 E Pike Street, Suite 1180

Seattle, WA 98122-3916

Or by e-mail  helpdesk@starweaver.com

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Safe Harbor Privacy Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the Starweaver web page (www.starweaver.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.

THIS SAFE HARBOR PRIVACY POLICY WAS LAST UPDATED ON 1 MARCH 2021.