EU-US & Swiss-US Privacy Shield Policy
SPK and Associates is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Pursuant to the Privacy Shield, SPK and Associates remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
SPK has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to a non-profit independent dispute resolution provider located in the United States, and operated by BBB National Programs, Inc. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by SPK, please visit https://bbbprograms.org/programs/all-programs/bbb-eu-privacy-shield-consumers/ProcessForConsumers for more information and to file a complaint.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
SPK’s Internet Privacy Commitment
We collect only personally identifiable information that is specifically and voluntarily provided by visitors to SPK’s website. SPK receives limited identifiable information, such as name, title, company address, email address, telephone and fax numbers from website visitors. Typically, identifying information is collected to:
- Register for certain areas of the site
- Inquire for further information
- Distribute requested reference materials
- Submit resumes
It is SPK’s policy to limit the information collected to only the minimum information required to complete a visitor’s request. In any instance where non-mandatory information is sought, the website visitor will be notified of this at the point of collection.
Although most publications are provided as free downloads, we do offer the opportunity to purchase SPK publications either online or by calling our toll free number. Customers pay by check and no credit card information is collected.
Visitors are also able to send email through the site. Their messages will contain the user’s screen name and email address as well as any additional information the user may wish to include in the message. Because we use the website as a recruiting tool, a visit to the website may also result in the user sending a resume to an individual within SPK.
EU, UK and Swiss individuals whose data we receive can address questions or comments regarding the handling of that information directly to us at email@example.com. We resolve to deal with all questions regarding this data and potential grievances arising from it in a timely manner. Note that under certain conditions we may, as a data processor, have to refer you to our client who is the data controller.
In the event SPK and Associates is unable to accommodate the individual’s request regarding data received by us within the context of the work relationship, we further commit to working with the Data Protection Authorities (DPA’s) who cover the jurisdiction the data originated from. For information on how to contact your jurisdiction’s DPA, visit: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
In the event SPK and Associates is unable to accommodate a Swiss individual’s request regarding data received by us within the context of the work relationship, we further commit to working with the Swiss Federal Data Protection and Information Commissioner (FDPIC) who covers the jurisdiction the data originated from. For information on how to contact your jurisdiction’s Commissioner, visit: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html.
SPK’s intention is not to seek any sensitive information through our website unless legally required for recruiting purposes. If you do wish to provide sensitive information for any reason, SPK accepts your explicit consent to use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.
Use of data
A user may choose to provide personal information in the following examples:
- Order publications
- Submit resumes or work history information
- Participate in “join our mailing list” initiatives
- Participate in bulletin boards, discussion or message forums
- Contact us for further information
- Enter Quick Surveys, Quiz’s or Benchmarking Surveys
- Register for events and conferences
If you would like to find out more about the different categories of information collected, please review the data collection section.
Information attained by the site is used only for the intended purpose stated at the time that the information is collected. This data is not shared with other entities in the network for secondary or unrelated purposes or shared with a third party, unless otherwise disclosed at the point of collection. If there is an instance where such information may be shared, the visitor will be asked for permission beforehand.
SPK may be required to disclose an individual’s personal information in response to a lawful request by public authorities including national security or law enforcement requirements.
SPK makes every practical effort to avoid excessive or irrelevant collection of data. If a visitor believes the site has collected excessive information, we encourage the visitor to contact us at: firstname.lastname@example.org to raise any concerns.
Cookies and log files
If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites; however other functionality in the site may be impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish.
In order to properly manage our website we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters. This is to ensure that our website presents the best web experience for visitors and is an effective information resource.
It is SPK’s policy only to disclose information to third parties under the following circumstances:
- As required by law through subpoena, search warrant or other legal process
- When explicitly requested by a visitor
- When required to deliver publications or reference materials requested by a visitor
- When required to facilitate conferences or events hosted by a third party
SPK’s policy is to disclose information to third parties upon visitors submitting their requests (e.g., when ordering a publication, we display the party fulfilling the order).
SPK and Associates is potentially liable for the onward transfer of data of EU and UK individuals received to third parties pursuant to the EU-US Privacy Shield.
Third party links
Some of the information we receive is not retained. Contact information about visitors (such as information generated though registration for access to areas on the site) will be kept as long as the information is required to completely service the contact request or until a user requests that we delete that information. Mailing list information, discussion posts and email are kept for only the period of time considered reasonable to facilitate the visitor’s requests. Resumes are disposed of when they are either no longer under consideration, or are considered dated by our Human Resources departments.
As a policy, visitors are not required to register to gain access to areas of the SPK websites. In certain cases in the future, as your SPK website experience expands, we may require visitors to register in order to obtain a user-id and password for authentication and secure access to a transaction or certain business confidential or proprietary information services on premium websites.
Personally identifiable information provided to SPK through its website is provided voluntarily by visitors. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate website area or in communications to our visitors.
Each visitor has the right of access to personal data they have submitted through SPK’s website. If you would like access to any personal information you have submitted, please contact SPK at: email@example.com.
SPK is committed to providing reasonable and practical access to visitors to allow them the opportunity to identify and correct any inaccuracies. When requested and practical, SPK will delete identifying information from current operational systems.
When personally identifiable information is retained, SPK assumes responsibility for keeping an accurate record of the information once a visitor has submitted and verified the data. SPK does not assume responsibility for verifying the ongoing accuracy of the content of personal information. When practically possible, if SPK is informed that any personal data collected through a website is no longer accurate, SPK will make appropriate corrections based on the updated information provided by the authenticated visitor.
SPK has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. All SPK employees follow a network-wide security policy. Only authorized SPK personnel are provided access to personally identifiable information and these employees have agreed to ensure confidentiality of this information. SPK’s policy is to use secure socket layer technology for the protection of credit card information submitted through web forms. This policy is also required for any fulfilment agents of our firms.
SPK understands the importance of protecting children’s privacy especially in an online environment. The SPK sites covered by this privacy statement are not intentionally designed for or directed at children 13 years of age or younger. It is SPK’s policy never to knowingly collect or maintain information about anyone under the age of 13.
SPK reserves the right to modify or amend this Statement at any time. The effective date will be displayed at the beginning of this statement. To keep visitors informed, SPK will notify users of changes to our Privacy Statement by prominently identifying the alteration for a period of not less than two weeks on our global home page at www.spkaa.com.